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(c) Measures
The following measures are designed to assist in preventing professional accountants from being used for money laundering
purposes:
■ developing programmes against money laundering and terrorist financing;
■ compliance officer;
■ employee training programme;
■ customer due diligence (CDD);
■ establishing/enhancing record keeping systems for:
– all transactions; and
– the verification of clients’ identities;
■ reporting of suspicious transactions;
■ refusing to have relationships with ‘shell banks’.
Tutorial note: Only FOUR are required.
Developing programmes
■ Internal policies, procedures and controls should be established and recorded including:
– compliance management arrangements (including appointment of a compliance officer);
– an ongoing employee training programme;
– an audit function to test the system.
Compliance officer
■ Appointing a compliance officer having a suitable level of seniority and experience (e.g. one of the principals of an
accountancy firm).
■ Making alternative arrangements (e.g. appointing a deputy) when the compliance officer is going to be unavailable for
a period of time (as reports have to be made as soon as is reasonably practicable).
■ The compliance officer being made responsible for:
– receiving and assessing money laundering reports from colleagues;
– making reports to the FIU; and
– ensuring that individuals are adequately trained.
Employee training programme
■ Providing an employee training programme on:
– relevant legislation (e.g. the main money laundering offences);
– ethical guidance (e.g. ACCA’s ‘Guidance for Accountants’); and
– the firm’s procedures to forestall and prevent money laundering.
■ Establishing a culture of complying with money laundering requirements.
■ Documenting the provision of training (to demonstrate compliance).
■ Training methods may effectively include:
– attending conferences, seminars and training courses run by external organizations; and
– participating in computer based training courses.
Customer due diligence (CDD)
■ Firms should not keep anonymous accounts or accounts in obviously fictitious names.
■ Firms should verify the identity of their customers, when:
– establishing business relations;
– carrying out occasional transactions (e.g. above a designated threshold);
– there is a suspicion of money laundering or terrorist financing; or
– there is doubt about the reliability or adequacy of previously obtained customer identification data.
CDD measures should include:
■ Identifying the customer and verifying that customer’s identity using reliable, independent source documents, data or
information.
Tutorial note: Similarly identify and verify the beneficial owner.
■ Obtaining information on the purpose and intended nature of the business relationship.
■ Conducting ongoing due diligence on business relationships by scrutinising transactions to ensure that they are
consistent with the firm’s knowledge of:
– the customer;
– their business and risk profile;
– the source of funds.
Tutorial note: These requirements should apply to all new customers and existing customers on the basis of materiality and
risk.
Record keeping
■ Maintaining all client identification records together with a record of all transactions, in a full audit trail form.
■ Maintaining records of transactions (both domestic or international) in a readily retrievable form. for a period of at least
five years (to facilitate swift compliance with information requests from the competent authorities).
Tutorial note: Such records must be sufficient to permit reconstruction of individual transactions (including the
amounts and types of currency involved, if any) so as to provide, if necessary, evidence for prosecution of criminal
activity.
■ Retaining client verification records throughout the period of the relationship and for five years after termination of the
relationship.
■ Making available identification data and transaction records to domestic competent authorities upon appropriate
authority.
■ Applying ACCA’s Rules of Professional Conduct ‘Retention of books, files, working papers and other documents’.
■ Paying special attention to all complex, unusual large transactions, and all unusual patterns of transactions, which have
no apparent economic or visible lawful purpose (in accordance with ISA 240 ‘The Auditor’s Responsibility to Consider
Fraud in an Audit of Financial Statements ’).
Client identification
■ For an individual – inspecting official documents, with a photograph, establishing the client’s full name and permanent
address, e.g:
– a driving licence or passport, supported by;
– a recent utility bill.
■ For the entity – obtaining from the Registrar of Companies:
– certificate of incorporation;
– company’s registered address; and
– a list of shareholders and directors.
■ Checking the names of new clients against lists of known terrorists and other sanctions information.
■ For trusts – ascertaining:
– the nature and purpose of the trust;
– the original source of funding; and
– the identities of the trustees/controllers, principal settlers and beneficiaries.
Suspicion reporting
■ Prompt reporting of suspicions to the (FIU) in a suspicious transaction report (STR).
■ There should be no ‘de minimis’ concessions. Reporting should be irrespective of:
– the amount involved; or
– whether tax matters are involved.
Tutorial note: Attempted transactions should also be reported.
■ Enhancing confidentiality of the source of reports by:
– disclosing the compliance officer only once; and
– not naming the personnel making reports to the compliance officer.
■ Disclosing further information only if:
– legally required to do so; or
– otherwise justified, in the public interest.
Shell banks
Tutorial note: A ‘shell bank’ is a bank incorporated in a jurisdiction in which it has no physical presence and which is
unaffiliated with a regulated financial group.
■ Firms should guard against relationships with parties that permit their accounts to be used by shell banks.

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1 ISLAND CO
(a) Briefing Notes
Subject: Principal Audit Risks – Island Co
Revenue Recognition – timing
Island Co raises sales invoices in three stages. There is potential for breach of IAS 18 Revenue, which states that revenue
should only be recognised once the seller has the right to receive it, in other words the seller has performed its contractual
obligations. This right does not necessarily correspond to amounts falling due for payment in accordance with an invoice
schedule agreed with a customer as part of a contract. Island Co appears to receive payment from its customers in advance
of performing any obligation, as the stage one invoice is raised when an order is confirmed i.e. before any work has actually
taken place. This creates the potential for revenue to be recognised too early, in advance of any performance of contractual
obligation. When a payment is received in advance of performance, a liability should be recognised equal to the amount
received, representing the obligation under the contract. Therefore a significant risk is that revenue is overstated and liabilities
understated.
Tutorial note: Equivalent guidance is also provided in IAS 11 Construction Contracts and credit will be awarded where
candidates discuss revenue recognition under IAS 11 as Island Co is providing a single substantial asset for a customer
under the terms of a contract.
Disputed receivable
The amount owed from Jacks Mine Co is highly material as it represents 50·9% of profit before tax, 2·3% of revenue, and
3% of total assets. The risk is that the receivable is overstated if no impairment of the disputed receivable is recognised.
Legal claim
The claim should be investigated seriously by Island Co. The chief executive officer’s (CEO) opinion that the claim will not
result in any financial consequence for Island Co is na?ve and flippant. Damages could be awarded against Island Co if it is
found that the machinery is faulty. The recurring high level of warranty provision implies that machinery faults are fairly
common and therefore the accident could be the result of a defective machine being supplied to Sawyer Co. The risk is that
no provision is created for the potential damages under IAS 37 Provisions, Contingent Liabilities and Contingent Assets, if the
likelihood of paying damages is considered probable. Alternatively, if the likelihood of damages being paid to Sawyer Co is
considered a possibility then a disclosure note should be made in the financial statements describing the nature and possible
financial effect of the contingent liability. As discussed below, the CEO, Kate Shannon, has an incentive not to make a
provision or disclose a contingent liability due to the planned share sale post year end.
A further risk is that any legal fees associated with the claim have not been accrued within the financial statements. As the
claim has arisen during the year, the expense must be included in this year’s income statement, even if the claim is still ongoing
at the year end.
The fact that the legal claim is effectively being ignored may cast doubts on the overall integrity of senior management, and
on the integrity of the financial statements. Management representations should be approached with a degree of professional
scepticism during the audit.
Sawyer Co has cancelled two orders. If the amounts are still outstanding at the year end then it is highly likely that Sawyer
Co will not pay the invoiced amounts, and thus receivables are overstated. If the stage one payments have already been made,
then Sawyer Co may claim a refund, in which case a provision should be made to repay the amount, or a contingent liability
disclosed in a note to the financial statements.
Sawyer Co is one of only five major customers, and losing this customer could have future going concern implications for
Island Co if a new source of revenue cannot be found to replace the lost income stream from Sawyer Co. If the legal claim
becomes public knowledge, and if Island Co is found to have supplied faulty machinery, then it will be difficult to attract new
customers.
A case of this nature could bring bad publicity to Island Co, a potential going concern issue if it results in any of the five key
customers terminating orders with Island Co. The auditors should plan to extend the going concern work programme to
incorporate the issues noted above.
Inventories
Work in progress is material to the financial statements, representing 8·9% of total assets. The inventory count was held two
weeks prior to the year end. There is an inherent risk that the valuation has not been correctly rolled forward to a year end
position.
The key risk is the estimation of the stage of completion of work in progress. This is subjective, and knowledge appears to
be confined to the chief engineer. Inventory could be overvalued if the machines are assessed to be more complete than they
actually are at the year end. Absorption of labour costs and overheads into each machine is a complex calculation and must
be done consistently with previous years.
It will also be important that consumable inventories not yet utilised on a machine, e.g. screws, nuts and bolts, are correctly
valued and included as inventories of raw materials within current assets.
Overseas supplier
As the supplier is new, controls may not yet have been established over the recording of foreign currency transactions.
Inherent risk is high as the trade payable should be retranslated using the year end exchange rate per IAS 21 The Effects of
Changes in Foreign Exchange Rates. If the retranslation is not performed at the year end, the trade payable could be
significantly over or under valued, depending on the movement of the dollar to euro exchange rate between the purchase date
and the year end. The components should remain at historic cost within inventory valuation and should not be retranslated
at the year end.
Warranty provision
The warranty provision is material at 2·6% of total assets (2006 – 2·7%). The provision has increased by only $100,000,
an increase of 4·2%, compared to a revenue increase of 21·4%. This could indicate an underprovision as the percentage
change in revenue would be expected to be in line with the percentage change in the warranty provision, unless significant
improvements had been made to the quality of machines installed for customers during the year. This appears unlikely given
the legal claim by Sawyer Co, and the machines installed at Jacks Mine Co operating inefficiently. The basis of the estimate
could be understated to avoid charging the increase in the provision as an expense through the income statement. This is of
special concern given that it is the CEO and majority shareholder who estimates the warranty provision.
Majority shareholder
Kate Shannon exerts control over Island Co via a majority shareholding, and by holding the position of CEO. This greatly
increases the inherent risk that the financial statements could be deliberately misstated, i.e. overvaluation of assets,
undervaluation of liabilities, and thus overstatement of profits. The risk is severe at this year end as Kate Shannon is hoping
to sell some Island Co shares post year end. As the price that she receives for these shares will be to a large extent influenced
by the balance sheet position of the company at 30 November 2007, she has a definite interest in manipulating the financial
statements for her own personal benefit. For example:
– Not recognising a provision or contingent liability for the legal claim from Sawyer Co
– Not providing for the potentially irrecoverable receivable from Jacks Mines Co
– Not increasing the warranty provision
– Recognising revenue earlier than permitted by IAS 18 Revenue.
Related party transactions
Kate Shannon controls Island Co and also controls Pacific Co. Transactions between the two companies should be disclosed
per IAS 24 Related Party Disclosures. There is risk that not all transactions have been disclosed, or that a transaction has
been disclosed at an inappropriate value. Details of the lease contract between the two companies should be disclosed within
a note to the financial statements, in particular, any amounts owed from Island Co to Pacific Co at 30 November 2007 should
be disclosed.
Other issues
– Kate Shannon wants the audit to be completed as soon as possible, which brings forward the deadline for completion
of the audit. The audit team may not have time to complete all necessary procedures, or there may not be time for
adequate reviews to be carried out on the work performed. Detection risk, and thus audit risk is increased, and the
overall quality of the audit could be jeopardised.
– This is especially important given that this is the first year audit and therefore the audit team will be working with a
steep learning curve. Audit procedures may take longer than originally planned, yet there is little time to extend
procedures where necessary.
– Kate Shannon may also exert considerable influence on the members of the audit team to ensure that the financial
statements show the best possible position of Island Co in view of her share sale. It is crucial that the audit team
members adhere strictly to ethical guidelines and that independence is beyond question.
– Due to the seriousness of the matters noted above, a final matter to be considered at the planning stage is that a second
partner review (Engagement Quality Control Review) should be considered for the audit this year end. A suitable
independent reviewer should be indentified, and time planned and budgeted for at the end of the assignment.
Conclusion
From the range of issues discussed in these briefing notes, it can be seen that the audit of Island Co will be a relatively high
risk engagement.