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ACCA Compliance review questionnaire

Firm’s name:

Contact partner:

Firm’s ref / visit ID Audit certificate: Y/N

Answer all of the questions. Some require only a yes or no, others require more detail.
Some additional information will need to be returned with the completed questionnaire as detailed
in the relevant sections below. If there is insufficient space in any section, please continue on a
separate sheet referenced to the relevant section.

Please note that this questionnaire relates to the firm named above only. If you or your
co-partners/directors are principals in other practising firms please list the firms below

SECTION A - Undertakings
Please read the following statements carefully before signing the declaration at the end. If you are
unable to give, in whole or part, any of the undertakings, select not confirmed from the drop-down
menu and provide a full explanation below.

1 Audit work *Delete as appropriate

I confirm that, in relation to the firm this questionnaire is addressed to, neither I
nor any other partner or director of this firm carries out any audits as a
Confirmed /
registered auditor. I am aware of the requirement for UK and Irish limited
Not Confirmed *
companies and certain other entities to be audited only by a registered auditor
(PR 5).

2 Reports to regulators
I confirm that neither I nor any other partner or director of this firm provides any
reports to regulators in respect of other clients for whom a regulatory or similar
Confirmed /
certificate is required (e.g. to the Financial Conduct Authority, the Solicitors
Not Confirmed *
Regulation Authority or ABTA / ATOL or on a Housing Association, Credit
Union or registered charity).

3 Future appointment
I confirm that I will notify ACCA, in writing, immediately if I, or any firm in which
I am a principal, accepts any audit appointment or appointment to provide a Confirmed /
report to a regulator in the future. Not Confirmed *

If you are unable to answer ‘confirm’ any of the above statements, please explain why below:

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SECTION B - Compliance with practising regulations

Where a question relates to a matter which is mandatory under ACCA's Global Practising
Regulations (GPRs) the relevant reference is stated. References to a Practising Regulation (PR
(UK)(IRE)) are to the regulations in Annex 1 to the GPRs, applicable to firms in the UK, Channel
Islands and Isle of Man and Annex 2 to the GPRs, applicable to firms in the Republic of Ireland.
The online version of ACCA's rulebook can be accessed on the website:
http://members.accaglobal.com/en/home/standards/rules-and-standards/rulebook.gl.html

1
Control - PR 8 (UK/IRE)

i Are you a sole practitioner? Yes / No


If you are not a sole practitioner, please provide a copy of the firm’s
partnership agreement or the latest annual return.

ii If your firm is a registered auditor and is a limited company, it needs to Yes / No / N/A
demonstrate that, even if the audit qualified individuals have control of
the shares of the firm, they also control the board of directors (PR 8(c))

Please provide a copy of the board agreement or minute showing that the
audit qualified individuals have the casting vote at any meetings of the
board of directors.

Has this been provided?


iii If you are not a sole practitioner please provide details of all the principals in the firm including
names, qualifications, office (partner or director) and voting control/shareholding.

Office
Name Qualification * Delete as appropriate Voting control/shareholding
Partner / Director*
Partner / Director*
Partner / Director*
Partner / Director*
Partner / Director*

2
Fitness and propriety - GPR8 / PR13(UK) / PR11(IRE)

i How many professional staff (excluding the principals) do you employ and how many
subcontractors do you use the services of:
Staff Subcontractors

ii Are you aware of anything which would potentially affect the fitness and propriety of:
Yourself Yes / No
Your partners/co-directors Yes / No
Your staff Yes / No
Your subcontractors Yes / No

iii Do your staff and subcontractors sign a declaration that they are fit and Yes / No
proper

iv Is this updated annually Yes / No


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If not, how often

v Are your staff and subcontractors required to sign a statement agreeing Yes / No
to keep client affairs confidential

vi Are fitness and propriety and confidentiality conditions of employment, Yes / No


which are included in a contract of employment

3 Professional indemnity insurance (PII) - GPR9 / PR14(UK) / PR12(IRE)


Y/end Y/end
Enter relevant dates here ____ xx/xx/xx xx/xx/xx
i What was the total income of your firm for its last two accounting years

ii What is the highest cumulative amount of fees raised to a particular client


during each of these years?

iii Have you had a claim from a client in the last six years Yes / No
If yes, please provide details

iv Are you aware of any current complaints from clients which may result in Yes / No
a claim

v Has there been any gaps in PII coverage Yes / No


If so, please explain

4
Continuity of practice - GPR11 / PR16(UK) / PR13(IRE)

i Have you made provision for the continuity of your practice in the event Yes / No
of your death or incapacity
ii Is the agreement Within your firm Yes / No
With another firm of accountants Yes / No
Provide name
iii Is this agreement in writing Yes / No

5 Notification (GPR 12 / PR17(UK) / PR15(IRE)

i Are there any other matters that require notification to ACCA under the Yes / No
regulations

ii If you have answered yes, please provide the details below

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6 Conduct GPR13 / PR18(UK) / PR16(IRE)
To be completed by all firms holding auditing registration only.

If your firm has audit registration, even if you do not currently hold audit appointments, you are required to
comply with the International Standard on Quality Control 1 (ISQC 1) and have written procedures in place
covering the following areas.

Do you have written procedures in place that comply with ISQC1? Yes / No

Explain how you have dealt with each of the following areas set out in ISQC 1

Engagement
acceptance and
continuance

Human
resources

Engagement
performance

Monitoring

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SECTION C – Compliance with Code of Ethics and Conduct (CEC)
Integrity, objectivity and independence and conflicts of interest
1
(CEC - sections 110, 120, 220 and 290)

i Are there any clients that pose a threat to your firm's being, or being seen to be, independent,
such as:
a Recurring fees at or above 15% of total fees Yes / No

b Long overdue fees Yes / No

c Litigation involving clients Yes / No

d Family or business relationships with clients Yes / No

e Shareholdings or trustee shareholdings in a client's company Yes / No

f Receiving gifts, hospitality or favourable terms from your clients Yes / No

Involvement in your clients business to the extent of being a shadow


g Yes / No
director

h Tight reporting deadlines imposed on you by your client Yes / No

i Unprofitable or fixed fee jobs Yes / No

j Other Yes / No
If other threats, please give details

ii If you have answered yes to any of the above, please give details of any safeguards you have
put in place, or explain why you do not consider that your firm's independence to be
threatened.

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2 Money laundering (CEC - section B2)

Money laundering is the process by which criminals attempt to conceal the true origin and
ownership of the proceeds of their criminal activity, often with the unwitting assistance of
professionals such as Accountants and Lawyers.

i Who is your firm’s Money Laundering Reporting Officer (MLRO)?

ii Has a Money Laundering Reporting Officer (MLRO) been formally appointed Yes / No

iii What internal controls have you established and recorded to ensure that anyone within your
firm who suspects money laundering knows how and who to report to

iv What training and guidance are staff given to ensure that they are able to identify unusual
transactions within a client’s business and is this knowledge updated regularly
(This applies to all staff and subcontractors who have any contact with clients)

v How do you verify new individual clients’ identities

vi How do you verify new corporate clients’ identities

vii What procedures do you have in place to carry out ‘customer due diligence’ to monitor the
business relationship and to keep your knowledge of the client up to date (including verifying
identities of existing clients)

*Guidance: “a PEP is a person who is or has, at any time in the preceding year been entrusted with a
prominent public function by a state other than the UK; a community institution or an international body or a
family member or known close associate of such a person”.
[Examples of PEPs – heads of state and government, members of parliaments, ambassadors, high ranking
officers in the armed forces]

viii Does your firm act for any Politically exposed persons (PEPs)* Yes / No

ix Even if you believe you currently have no PEPs, please explain how you identify if a client is a
Politically exposed persons (PEPs).

x Should you accept a PEP what additional due diligence procedures would you have in place
for them.

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xi What records do you keep for the following :
Staff training on MLR issues

Confirmation of Client identities

Customer Due diligence

Internal reports to MLRO

How long do you keep the above records for?

xii Who (external body) should the firm report


any suspicions to

xiii Define ‘Tipping off’ and explain the ramifications.

3 Professional appointments (CEC - section 210)


Does your firm always obtain professional clearance before starting
work on a new client’s affairs Yes / No
If no, please explain your procedures below

4 Engagement letters (CEC - section B9)


Do you issue engagement letters to all your clients Yes / No

If no, please specify which categories of clients you have not issued engagement letters to:

5 Client money (CEC - section 270)


Members in practice are strictly accountable for all clients’ monies which they receive and are required to
comply with the requirements set out in ACCA’s Code of Ethics and Conduct.
i Do you receive money from third parties or hold money on
Yes / No
behalf of your clients

Do you make payments to third parties on behalf of your


ii Yes / No
clients

iii If yes, to either of the above, approximately how many


transactions have there been in the last 12 months

iv Do you have a designated client bank account with the word


Yes / No
‘client’ in the title

v Does the bank have the right to set off balances on this
Yes / No
account against balances on your office accounts

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vi What records do you keep of transactions in your client bank
account

vii How often do you reconcile the client account

viii How often do you analyse the balance between clients

ix Are any client tax refunds paid into the office account Yes / No

SECTION D – Compliance with Designated Professional Body Regulations (DPBRs)


To be completed by firms resident or conducting business in the UK only

1 Does your firm undertake any of the following activities


i Regulated mortgage work Yes / No

ii Long term care insurance (LTCI) Yes / No

iii Other (i.e. non LTCI) insurance mediation Yes / No

iv Non-insurance based incidental investment business Yes / No

v If you answered yes to any of the above, please provide details

2 Does your firm offer fee protection insurance to your clients Yes / No
If the answer is yes, please answer the following questions:
i Does the invoice show VAT or IPT

ii Where are the bank account receipts, in the office account or clients
account?

iii Who makes the claim; the firm or the client?

3 Does your firm earn any commission from investment business related
Yes / No
services
If the answer is yes, when and how do you inform your client

4 Even if you are not registered for DPBRs, explain what you do if a client asks your firm for
advice on an investment business related matter

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SECTION D – Irish Investment Business Regulations (IIBRs)
To be completed by firms resident or conducting business in the Republic of Ireland only

1 Does your firm advise on, or arrange transactions that are regulated
under the Irish Investment Business regime?
This will include advising or arranging transactions on any of the following
products: Life assurance policies, including pensions; non-life insurance Yes / No
policies; personal retirement savings accounts; unit trusts; collective
investment scheme instruments; listed shares and bonds; tracker bonds;
prize bonds; bank deposits; film investments; or BES investments.

If you answered yes to the above, please provide details

SECTION E – General information

1 What is your firms expected fee income for the current year?

2 How many staff do you employ in total including subcontractors?

3 Please indicate which of the following services you provide and an approximate
percentage for each (accumulating to 100%)
Accounts prep Yes / No %
Audit Yes / No %

Reports to regulators Yes / No %


Company tax compliance Yes / No %

Personal tax compliance Yes / No %

Payroll & related tax compliance Yes / No %

VAT/sales tax compliance Yes / No %

Bookkeeping services Yes / No %

Management accounts Yes / No %


Consultancy, business advice and tax planning services Yes / No %

Projections, cash-flows and budgets Yes / No %

Due diligence work Yes / No %

Share Valuations Yes / No %


Other services – please give details
%
%
%

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ATTACHMENTS

Please ensure you have submitted the following copy documentation to email to ACCA:

If you are not a sole practitioner, the firm’s partnership agreement or the
1a Yes / No / N/A
latest annual return as evidence of control of the firm.
If your firm is limited company and a registered auditor, a copy of the
1b board agreement or minute, as evidence that audit qualified principals Yes / No/ N/A
have the control over the matter.
2 A copy of the firm’s letterhead Yes / No
A copy of the current schedule of cover for your firm’s professional
3 Yes / No
indemnity insurance (PII)

4 A copy of the full PII policy Yes / No

5 A copy of the last PII proposal form you completed Yes / No


Details of any claims or matters notified to your insurers in the last six
6 Yes / No / N/A
years

A copy of the written continuity agreement, partnership agreement or


7 memorandum and articles of association as relevant to the continuity Yes / No
arrangements you have in place

An example of an engagement letter for each of a corporate and a non-


8 Yes / No
corporate client.

Please find the link to the ACCA Monitoring “best practice” review
questionnaire in the cover email. Completion of the questionnaire is
mandatory. Please confirm if this has been completed. If no provide a Yes / No
reason why not.

Email this completed questionnaire, together with the copy documentation you
have prepared to: qualitychecked@accaglobal.com

SECTION F – Declaration

By submitting this form to the ACCA I confirm that the information I have provided above and that
included in the enclosures is true, accurate and complete to the best of my knowledge and belief.

Name:

Position in firm:

Name of firm:

Date:

If you have any further information you wish to disclose please do so in the box below

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