The FRC has published its consultation (the “Consultation”) on proposed updates to the FRC’s Audit Enforcement Procedure (“AEP”). The Consultation stresses that – while investigations are “an essential part” of the FRC’s enforcement regime – the proposals intend to make explicit how the ‘public interest’ is embedded in the FRC’s decision-making.
While raising the bar for enforcement action under the AEP will be welcomed by industry, the proposed amendments to the AEP are nonetheless novel and complex. With the proposed introduction of new routes to resolution, might there be more red-tape and regulation for compliance teams to digest?
Beyond that, it remains to be seen how frequently and under what circumstances the FRC chooses to go down these alternative routes to resolution and what the ancillary updated “public interest” guidance means for firms and individuals in this space.

For further information, please contact:
Gavin Lewis, Partner, Linklaters
gavin.lewis@linklaters.com




