by John McCarthy Consulting Ltd. | May 1, 2026 | Blog, News
Concluding our three-part series on Audit Hot Topics for 2026, last week and the week before we looked at some of the main areas that are topical at the moment. This week we look at a further tranche of issues to remind auditors as the audit season for SME entities commences.
Independence issues
Common pitfalls around audit independence include situations where:
- Individuals within firms, or entities related to the audit firm act as company secretary to audit clients or as trustee for a trust with a material interest in an audit client; and
- non-audit services provided on a contingent fee basis (normally linked to capital allowances claims, research and development tax claims or similar work) are provided.
SoQM
So that a System of Quality Management (SoQM) can be effective it needs to include:
- appropriate administrative and accounting procedures;
- an internal/external quality control process (typically hot and cold file reviews);
- effective procedures for risk assessment, and
- effective control and safeguard arrangements for the information processing system used by the audit firm i.e. data security.
If your firm needs assistance with its SoQM implementation and compliance with the ISQM 1 standard, please see our website store for the ISQM Toolkit.
Audit evidence and documentation
Many of the audit cold file review findings relate to documentation weaknesses. A very useful guidance document was published by the Chartered Accountants Ireland in March 2026 called ‘Guidance for audit evidence and documentation’ which will be a great help to audit teams to improve their audit documentation.
Our audit file review service is available either on-site or remotely where we will provide you with a written report benchmarking your audit file against the appropriate standards. You will receive a gap analysis of where your firm stands on a particular assignment within clear direction as to appropriate action to consider for improvement.
For those of you still in the process of ISQM 1 implementation, please see our ISQM TOOLKIT or if you prefer to chat through the different audit risks and potential appropriate responses presented by this new standard, please call or e-mail John McCarthy FCA or e-mail him at john@jmcc.ie.
We typically tailor training and brainstorming sessions to suit each firm’s unique requirements.
Publications and AML webinar:
-
- The ISQM TOOLKIT 2022 is available to purchase here.
- See our latest Anti-Money Laundering Policies Controls & Procedures Manual (March 2022) – View the Table of Contents click here.
- Also we have an updated AML webinar (March 2022) available here, which accompanies the AML Manual. It explains the current legal AML reporting position for accountancy firms and includes a quiz. Upon completion, you receive a CPD Certificate of attendance in your inbox.
- To ensure your letters of engagement and similar templates are up to date visit our site here where immediate downloads are available in Word format. A bulk discount is available for orders of five or more items if bought together.
by John McCarthy Consulting Ltd. | Apr 27, 2026 | Blog, News
Continuing our three-part series on Audit Hot Topics for 2026, last week we looked at some of the main areas that are topical at the moment. This week we look at some more to act as a reminder to auditors as the audit season for SME entities commences.
Revenue
Revenue is always one of the most significant items in any set of financial statements and is often a significant risk area. Weaknesses in testing are common in the testing of revenue, especially in the areas of:
and it’s important for audit teams to commence the testing from outside the client accounting system i.e. from the sales order (external), not from the sales invoice (internal).
Journals testing (ISA 315)
Journals entries processed at the client entity must always be tested, but many files are lacking evidence that this work is done.
Some audit firms are making good use of technology to test journals, like data analytics within Excel or specialised data analytics tools but it’s important to define the outliers you are looking for in the software so that they are appropriately tailored to the audit entity.
Accounting Estimates ISA 540
Everyone acknowledges that the audit of accounting estimates is a difficult area. Auditors need to appropriately challenge the method, assumptions and data used in the determination of the estimate. Sometimes this may involve having discussions with experts, like quantity surveyors, pensions actuaries and property valuation experts.
This communication should document an assessment and evaluation of the expert’s qualifications, experience and independence, but also challenge the expert’s approach to calculate the estimate.
Our audit file review service is available either on-site or remotely where we will provide you with a written report benchmarking your audit file against the appropriate standards. You will receive a gap analysis of where your firm stands on a particular assignment within clear direction as to appropriate action to consider for improvement.
For those of you still in the process of ISQM 1 implementation, please see our ISQM TOOLKIT or if you prefer to chat through the different audit risks and potential appropriate responses presented by this new standard, please call or e-mail John McCarthy FCA or e-mail him at john@jmcc.ie.
We typically tailor training and brainstorming sessions to suit each firm’s unique requirements.
Publications and AML webinar:
-
- The ISQM TOOLKIT 2022 is available to purchase here.
- See our latest Anti-Money Laundering Policies Controls & Procedures Manual (March 2022) – View the Table of Contents click here.
- Also we have an updated AML webinar (March 2022) available here, which accompanies the AML Manual. It explains the current legal AML reporting position for accountancy firms and includes a quiz. Upon completion, you receive a CPD Certificate of attendance in your inbox.
- To ensure your letters of engagement and similar templates are up to date visit our site here where immediate downloads are available in Word format. A bulk discount is available for orders of five or more items if bought together.
by John McCarthy Consulting Ltd. | Apr 20, 2026 | Blog, News
Audit Quality and ISQM
There are no major imminent changes to the ISAs Ireland for auditors of SME entities in Ireland during this reporting season, but there is a lot for auditors to think about in terms of audit quality. Recent reports from the CAI indicate that audit quality is still a burning topic. These topics were among those touched upon during the recent online Audit Conference organised by the Chartered Accountants Ireland.
Positive Conformation Requests Now Mandatory
Be aware of ISA 505 ‘External Confirmations’ which effectively bans negative confirmation requests. This became mandatory for accounting periods commencing on/after 15 December 2024, which in reality means audits for the years ending 31 December 2025.
A negative confirmation request is ‘a request that the confirming party respond directly to the auditor only if the confirming party disagrees with the information provided in the request.’ In most cases, in our experience, negative confirmations are hardly ever used in practice.
Positive external confirmation requests are defined as ‘a request that the confirming party respond directly to the auditor indicating whether the confirming party agrees or disagrees with the information in the request or providing the requested information.’
The most common of these would be debtor circularisation’s.
Obtaining Audit Evidence ISA 500
All firms need to constantly improve the documentation around obtaining audit evidence. The main areas for focus in this regard include:
Analytical Procedures ISA 520
The use of analytical procedures often brings significant benefits when used as a substantive audit procedure. Among the benefits are:
- They can provide strong audit evidence and
- They can assist the auditor gain a better understanding of the audited entity.
It is not uncommon that analytical procedures (especially at the planning stage of the audit) are not completed to a sufficiently high standard and not in the predictive way that is required. For example, simple comparisons between years do not provide sufficiently high-quality audit evidence. The comparisons need to be accompanied by commentary that is well informed about the client’s industry along with links to external news and industry insight reports and data that is sourced independently of the client entity.
Sampling ISA 530
The Financial Reporting Council removed sample size caps some years ago and this development has caused auditors no little stress. It’s always possible to justify sample size selection by professional judgement but this is often poorly documented.
It’s also important to ensure that all elements of the client’s target population have an equal opportunity of being selected across the financial period under review.
Our audit file review service is available either on-site or remotely where we will provide you with a written report benchmarking your audit file against the appropriate standards. You will receive a gap analysis of where your firm stands on a particular assignment within clear direction as to appropriate action to consider for improvement.
For those of you still in the process of ISQM 1 implementation, please see our ISQM TOOLKIT or if you prefer to chat through the different audit risks and potential appropriate responses presented by this new standard, please call or e-mail John McCarthy FCA or e-mail him at john@jmcc.ie.
We typically tailor training and brainstorming sessions to suit each firm’s unique requirements.
Publications and AML webinar:
-
- The ISQM TOOLKIT 2022 is available to purchase here.
- See our latest Anti-Money Laundering Policies Controls & Procedures Manual (March 2022) – View the Table of Contents click here.
- Also we have an updated AML webinar (March 2022) available here, which accompanies the AML Manual. It explains the current legal AML reporting position for accountancy firms and includes a quiz. Upon completion, you receive a CPD Certificate of attendance in your inbox.
- To ensure your letters of engagement and similar templates are up to date visit our site here where immediate downloads are available in Word format. A bulk discount is available for orders of five or more items if bought together.
by John McCarthy Consulting Ltd. | Mar 24, 2026 | Blog, News
New anti-money laundering (AML) legislation is expected to be enacted in Ireland in at least two tranches on or before 10 July 2026 and 10 July 2027.
In this blog and in the coming weeks we summarise the points of most interest to accountants in practice, based on the Technical Alert 05/2025 (TA) issued by Chartered Accountants Ireland in December 2025. There are more details in the TA itself.
These AML laws will complete the implementation of the European Union 6th Anti Money laundering package which was enacted by the EU on 9 July 2024.
These laws comprise two parts:
- A Regulation called the AML Regulation (EU) 2024/1624) which is about the prevention of the use of the financial system for the purposes of money laundering or terrorist financing.
- A Directive called the AML Directive (EU) 2024 /1640) on the mechanisms to be put in place by Member States for the prevention of the use of the financial system for the purposes of money laundering or terrorist financing.
As we know from the GDPR (Data Protection Regulation from 2018) regulations must be implemented across the EU Member States without any local changes, whereas Directives permit some minimal local variation.
These new rules will be overseen by the new Europe wide AML Regulator called the Anti-money Laundering Authority (AMLA).
For the time being accountants should refer to the existing up to date AML guidance for accountants in Ireland called Technical Release 01-2019 (Updated March 2022) AML Guidance for CCAB-I members. This guidance will need refreshed when the new legislation comes into effect.
The main changes coming into place include:
- Independent Audit Function – As part of the accountancy firm’s internal policies, procedures and controls entities are required to have in place an independent audit function to test the internal policies and procedures and the controls in place in the firm. Where such an independent audit function is not present within the firm, it may have the test carried out by an external expert.Firms must ensure that the person responsible for the AML audit function can report directly to the management body. Independent audit appears to be mandatory under the AML Regulation.
Firms will also be required to take measures to ensure employees, agents and subcontractors like are aware of AML requirements and these measures include participation of those employees, agents and subcontractors in specific ongoing AML training programmes that show them how to recognise operations which may be related to money laundering or terrorist financing and to show them how to proceed in such cases.
- Integrity and Honesty Assessment – Article 13 of the AML Regulation requires firms to assess employees, agents and subcontractors who directly participate in the firm’s AML compliance functions as having appropriate skills, knowledge and expertise to carry out their functions effectively including an assessment of their honesty and integrity and whether they are of good repute.
How can John McCarthy Consulting help?
Our audit file review service is available either on-site or remotely where we will provide you with a written report benchmarking your audit file against the appropriate standards. You will receive a gap analysis of where your firm stands on a particular assignment within clear direction as to appropriate action to consider for improvement.
For more on engagement and representation letter templates and a variety of CPD webinars on money laundering and other accounting/audit related topics, please go to our website for:
- Anti-Money Laundering Policies Controls and Procedures Manual (March 2022) — View the table of contents
- Letters of engagement and similar templates—Please visit our website here where immediate downloads are available in Word format. A bulk discount is available for orders of five or more items bought together.
- ISQM TOOLKIT, or if you prefer to chat through the different audit risks and potential appropriate responses presented by this new standard. We typically tailor ISQM training and brainstorming sessions to suit your firm’s unique requirements. Please contact John McCarthy FCA by email at john@jmcc.ie.
by John McCarthy Consulting Ltd. | Mar 21, 2026 | Blog, News
If you have clients in the high value goods dealer (HVGD) sector, then you will need to be aware of this case.
According to the website of the AML Compliance Unit of the Department of Justice HVGDs ‘are businesses involved in the sale of goods of high value where the trader accepts cash payments of €10,000 either in one transaction or a series of linked transactions. Examples of these businesses include antique dealers, boat and car sales, dealers in precious stones, jewellers.’
In a recent February 2026 case the Dutch branch of Louis Vuitton suffered a €500,000 penalty in an out of court settlement, for significant violations of the Money Laundering and Terrorism Financing Prevention Act in the Netherlands.
The underlying criminal case against the three individuals involved remains active, reflecting a trend where regulatory authorities often prioritize corporate accountability through financial sanctions while simultaneously pursuing criminal prosecutions against the specific actors who orchestrated the laundering scheme. The three main suspects face prosecution in a Rotterdam court.
The sanction followed a comprehensive police investigation into a sophisticated money laundering network that utilized luxury retail channels to disguise the origins of criminal proceeds.
The company was found guilty of falling short of the AML requirements by allowing a single customer to conduct a series of high-value transactions without triggering the necessary internal red flag alerts or verification procedures. The failure to monitor and report suspicious activity enabled a criminal organization to convert more than €2 million in cash payments over a multiyear period from 2021 to 2023.
HVGD retailers are expected to not only:
- Identify their customers, but also
- Investigate the source of funds when transactions meet certain risk profiles.
In this case, Louis Vuitton allegedly ignored multiple red flags, including the frequent use of different aliases by a recurring customer and the sheer volume of physical currency being exchanged for designer handbags. The acquisition of these goods was not for personal use but was instead a critical step in a value transfer process known as the Daigou trade. The UK National Crime Agency produced a detailed report on the Daigou AML phenomenon in 2019.
The Daigou model involves the purchase of luxury items in Western markets for resale in territories where such goods are more expensive or heavily taxed, such as China. The use of luxury retail items as a vehicle for laundering is particularly attractive to criminal groups because these products maintain high resale value and are easily transportable.
From 1 January 2026, the Netherlands has implemented a ban on accepting cash payments of €3,000 euros or more for professional sellers of goods. This same €3,000 threshold will apply in Ireland once legislation enacting the 6th AML Directive comes into force within the next two years.
This legislative change is specifically designed to eliminate the room for manoeuvre previously enjoyed by those who structured payments just below the old €10,000 threshold, which still applies in Ireland for the time being.
How can John McCarthy Consulting help?
Our audit file review service is available either on-site or remotely where we will provide you with a written report benchmarking your audit file against the appropriate standards. You will receive a gap analysis of where your firm stands on a particular assignment within clear direction as to appropriate action to consider for improvement.
For more on engagement and representation letter templates and a variety of CPD webinars on money laundering and other accounting/audit related topics, please go to our website for:
- Anti-Money Laundering Policies Controls and Procedures Manual (March 2022) — View the table of contents
- Letters of engagement and similar templates—Please visit our website here where immediate downloads are available in Word format. A bulk discount is available for orders of five or more items bought together.
- ISQM TOOLKIT, or if you prefer to chat through the different audit risks and potential appropriate responses presented by this new standard. We typically tailor ISQM training and brainstorming sessions to suit your firm’s unique requirements. Please contact John McCarthy FCA by email at john@jmcc.ie.
