Tag: Audit

  • The FRC’s Professional Judgement Guidance

    In the auditing profession, technical competence is merely the entry requirement. The true hallmark of a high-quality auditand the primary defense against material misstatement is the effective exercise of professional judgement. Recognizing that poor judgement is a recurring theme in quality failures, the Financial Reporting Council (FRC) issued comprehensive guidance in June 2022 to provide auditors with a structured, rigorous approach to decision-making.

    While this guidance is non authoritative, it encapsulates “good practice” that the FRC expects firms to analyze and integrate into their own internal frameworks. We have summarised some of their key points, however please refer to the document in the link above to read their full guidance.

    Understanding the Framework

    The FRC defines professional judgement as the application of relevant training, knowledge, and experience within the context of auditing, accounting, and ethical standards to make informed decisions. This isn’t just about “big” decisions like going concern; it permeates every level of an audit, including resourcing, task allocation, and firm-level quality management.

    The FRC’s framework is built upon four pillars designed to ensure consistency and quality:

    1) The Auditor’s Mindset

    A robust judgement begins with the right mental posture. The framework identifies five critical mindset aspects:
    Public Interest Benefits: Understanding that the audit acts for the benefit of intended users helps motivate objectivity and a commitment to quality.

    Professional Scepticism: Maintaining a questioning mind and critically assessing evidence is vital, especially when challenging management assertions.

    Psychological Factors and Bias Awareness: Auditors must actively guard against “judgement traps” and bias:


    Sensitivity to Uncertainty: Acknowledging that information sources vary in reliability and that some outcomes are inherently uncertain allows for better risk management.

    Commitment to Quality: Prioritizing a robust process over time or budget pressures is essential for reaching reasonable conclusions.

    The Professional Judgement Process

    While judgement is rarely linear, the FRC suggests a structured process for complex issues:

    Trigger: Remaining alert to situations that require more than an intuitive evaluation.

    The Right Person: Ensuring the individual making the decision has the necessary skills and resources, and escalating issues when they exceed one’s experience.

    Framing the Issue: Defining the problem, articulating objectives, and identifying all viable alternatives to avoid narrow thinking.

    Marshalling Information: Seeking out diverse data sources, including “external signals” outside the entity’s finance function.

    Analysis and Evaluation: Evaluating the relevance and reliability of the gathered information in the context of the judgement.

    Stand Back and Conclude: Pausing to view the preliminary conclusion in the round to ensure it hasn’t been unduly affected by bias or time pressure.

    Document, Communicate, and Reflect: Recording the rationale for the decision, explaining it to stakeholders, and reflecting on the process to improve future judgements.

    3) Consultation

    Quality is significantly enhanced by discussion. Engaging with technical panels, experts, or engagement quality reviewers helps mitigate individual biases and fosters a culture of healthy debate within the firm.

    4) Environmental Factors

    Auditors do not work in a vacuum. The framework acknowledges that firm culture, time constraints, and the integrity of management at the audited entity all significantly impact how challenging it is to exercise quality judgement.

    Illustrative Examples in Practice


    To show how these principles apply in the real world, the FRC provides three fictional scenarios.

    Example 1: The “Window Dressing” Disclosure

    Scenario: A manufacturing company significantly increases its cash balance just before year-end by delaying supplier payments and offering customer discounts, resulting in a deceptively low “net debt” figure in the notes.

    The Judgement: The auditor must decide if the disclosure is materially misstated because it obscures the entity’s true financial position throughout the year.

    The Application: The auditor demonstrates scepticism by questioning management’s “commercial reasons” and researches industry peers to see how they disclose average net debt. This highlights the need to “frame” the issue around user needs and fair presentation rather than just technical accuracy.

    Example 2: The “Close-Call” Going Concern

    Scenario: A group recovers from the pandemic but faces debt refinancing risks. Management claims there is no material uncertainty, pointing to informal bank support and shareholder letters of intent.

    The Judgement: The engagement partner must determine if a “material uncertainty” exists regarding going concern.

    The Application: Despite intense pressure from management to sign off quickly, the partner consults with her firm’s ethics and technical teams. This illustrates how environmental factors (time pressure) can threaten quality and the importance of using safeguards like consultation to mitigate threats to objectivity.

    Example 3: The Hostile Audit Committee

    Scenario: Following a delay in an audit caused by late and incomplete management papers on goodwill impairment, a hostile Audit Committee threatens to put the audit out to tender.

    The Judgement: The audit firm must decide whether to continue the relationship for the next year.

    The Application: An internal panel assesses the integrity of the client’s governance and the appropriateness of the team’s challenge. This example warns against “motivated reasoning”—the firm must ensure that financial priorities (profitability of the audit) do not lead to an inappropriate decision to continue if the client lacks integrity or ethical values.

  • Bitcoin audit

    Bitcoin audit

    bitcoin audit

    Why would a Bitcoin audit be required?

    The New York State Department of Financial Services have proposed Bitlicense regulations which would require licensees to submit audited annual financial statements. If these regulations are passed it is possible that authorities in other jurisdictions would implement similar requirements.

    For example, we note that online gambling was initially illegal in many jurisdictions around the world, but one by one, governments have been licensing operators and subjecting them to heavy taxes.

    However, even if Bitcoin audits do not become mandatory, it could become best practice for Bitcoin businesses to undergo an audit of their financial statements. Many Bitcoin exchanges have already had independent tests to prove their level of Bitcoin reserves so the next step could be to have their financial statements audited.

    A Bitcoin audit could be also be required in the UK if a company exceeds the small company limits or is deemed to be an ineligible company.

    What does an audit of financial services generally involve?

    In the UK, a company has to produce a set of annual accounts in accordance with generally accepted accounting principles (eg UK GAAP or IFRS) and Companies Act 2006. However, if a financial director produces a set of accounts, how would a user or reader of the accounts know whether or not they can trust its contents?

    An auditor will independently verify whether the accounts are true and fair and in compliance with the applicable laws and regulations. The auditor will need to be suitably qualified, be named on the Audit Register and will need to perform the audit in accordance with International Standards on Auditing.

    An auditor will obtain a full understanding of the business and the industry in order to perform a risk analysis and to plan the audit. They’ll need to consider what the key balances and transactions are and which ones are most susceptible or fraud or error.

    Once the audit has been planned they’ll work through the accounts to verify and corroborate the assets, liabilities income and expenses that have been included in the accounts and also to test for any significant transactions or balances which have been omitted.

    Key risks for a Bitcoin audit

    A Bitcoin business would have assets, liabilities and transactions denominated in Bitcoin. Key risks would include whether Bitcoin assets (eg reserves in cold storage) and liabilities (eg customer deposits) exist, are correctly valued and whether they are complete.

    It may be possible to obtain sufficient, appropriate evidence about existence and completeness for exchanges by using an approach similar to that used by Stefan Thomas and his tools such as Easy Audit. Other Bitcoin businesses may need different techniques. Depending on the type of Bitcoin business and the complexity of its transactions, an auditor may require a cryptographer or IT specialist to perform such procedures in order to comply with ISA 620.

    Bitcoins are likely to be treated as a cash equivalent/ foreign currency or as an investment, depending on how the business uses them and its intentions. In order to ensure they’re correctly valued, they would need to be translated into the base currency used in the financial statements (eg £ in the UK) and an adjustment may be required depending on the accounting policy.

    A Bitcoin business is likely to be involved in online transactions and the transfer of funds, so internal controls and anti-money laundering procedures are also likely to be key areas for a Bitcoin audit.

    We can help

    Our team have audited both financial services businesses and e-commerce businesses and can use this experience to help us audit a Bitcoin business efficiently and effectively.

    For example, a large online gaming businesses had millions of customer accounts and we had to verify the total liabilities owed to customers, as well as testing a sample of individual deposit/withdrawal transactions and interactions with payment gateways.

    The financial services businesses we audit have complex accounting/tax rules such as mark to market/fair value and also strict rules for anti-money laundering and dealing with client money.

    Please contact us for assistance and we’ll be happy to offer a free consultation where possible.