by John McCarthy Consulting Ltd. | Jan 13, 2026 | Blog, News
The fallout from the Wirecard saga is still ongoing with the latest news on the jailing of two more individuals on 6 January 2026 as reported in the Straits Times (the Times).
The two individuals are Singaporean R. Shanmugaratnam (59), who was earlier was sentenced to 10 years’ jail on Jan 6 and Briton James Henry O’Sullivan, 51, who had abetted Shanmugaratnam, who was sentenced to 6½ years’ in jail. A district court found them guilty of their charges in September 2025 after a trial.
The Times reports that Shanmugaratnam received a request in February 2016, from auditors Ernst & Young (EY) for an entity that he represented called Citadelle to confirm the balance of all accounts held by Wirecard AG and/or its subsidiaries with Citadelle as of 31 December 2015.
Citadelle allegedly confirmed that it held money in escrow accounts for various Wirecard entities across three financial years, but this was not true.
The bottom line for auditors is that verifying the veracity of bank enquiry responses is absolutely critical on audit assignments and more emphasis needs to be placed on following up incorrect or incomplete responses from financial institutions. The relevant Irish audit standard is ISA 505 (March 2024) from the Irish Auditing & Accounting Supervisory Authority
For audit cold file reviews and tailored training sessions explaining more about various topics like AML, Audit, FRS 102, please send a mail to john@jmcc.ie.
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:
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. | Dec 10, 2025 | Blog, News
Although published in July 2025, the 2024 Annual Report of the Department of Justice AML Compliance Unit (AMLCU) did not attract the attention it deserved at the time.
While the overall number of AML reports fell by 12% (60,753 versus 68,998 in 2023) compared to the 2023 level, the numbers of AML reports from accountants doubled to 30. AML reports from auditors are recorded separately and there were 10 of those in 2024.
The number of AML reports from accountants in the last five years were as follows:
- 2024 – 30
- 2023 – 15
- 2022 – 9
- 2021 – 33
- 2020 – 11
While most accountants are inspected for AML purposes by their professional body, those self-employed accountants not already supervised by a professional body are inspected by the AMLCU and in 2024, 81 were inspected, including tax advisors.
The results of these 81 inspections in 2024 are as follows:
| |
Compliant |
Partial |
Non-Compliant |
N/A, Other* |
| External Accountant |
20 |
14 |
4 |
16 |
| Tax Advisor |
7 |
3 |
2 |
15 |
| |
27 |
17 |
6 |
31 |
- *Other includes: Not a designated person; unannounced inspections of a suspected TCSP operating without authorisation; entity no longer trading.
For audit cold file reviews and tailored training sessions explaining more about various topics like AML, Audit, FRS 102, please send a mail to john@jmcc.ie.
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:
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. | Dec 10, 2025 | Blog, News
As we reported in April 2025, the AMLA (Anti-Money Laundering Authority) had its first meeting in March 2025. Since then, it has been adding more personnel, growing to a current December 2025 complement of 100 staff (about 20 behind the original plan), with 70 joining in the last three months. The AMLA is based in Frankfurt.
The chair of AMLA is Milanese lawyer, Bruna Szego. Since commencing her role on 1 July 2025, she has visited 25 Member States and met supervisors, Financial Intelligence Units (FIUs), and industry representatives.
On 2 December 2025 she appeared before an EU Parliament Committee (video recording here – start at 10 minutes in) and her key takeaway was that ‘while the financial sector understands its role, the non-financial sector lags behind. The landscape there is fragmented, with many obliged entities facing real challenges in applying even basic controls due to cost and lack of reliable information.’
The future timeline for AMLAs development, according to its own website, is as follows:
- 2026 – Gradual ramping up of IT business service and assessment of AMLA’s future IT needs
- 2027 – 40 obliged entities are selected to be directly supervised
- 2027 – at the end of 2027 AMLA staff reaches a cruising capacity of about 430
- 2028 – Start of direct supervision, with AMLA fully operational
For audit cold file reviews and tailored training sessions explaining more about various topics like AML, Audit, FRS 102, please send a mail to john@jmcc.ie.
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:
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. | Nov 16, 2025 | Blog, News
The Chartered Accountants Ireland last month filed its response to the FRC consultation about the draft Practice Note on the Audit of Less Complex Entities.
The PN is basically the updated version of the much loved PN 26 Guidance on Smaller Entity Audit Documentation which was withdrawn in 2016. The latest version still has the same hotel/restaurant case study example (Bulls Restaurant and Hotel) but with updated references to the latest ISAs and the latest technology.
While the Institute supports the development of additional guidance in principle as small and medium-sized practices need to be able to apply the ISA proportionately to the scale of their audit clients. The Institute prefers that the FRC would focus on the IAASB standard called the International Standard on Auditing for Audits of Financial Statements of Less Complex Entities (ISA for LCE’), which is better customized for the needs or SME audit market.
Among other things, in its response, the Institute has called for:
- Better alignment/mapping to the underlying ISAs, which would aid ease of reference when navigating the ISAs;
- More guidance and examples on the calculation of performance materiality including how firms should document the rationale for calculations used and use of associated benchmarks to support calculation of performance materiality;
- Enhancements to the PN such as examples regarding:
- documentation of professional judgement;
- further guidance and examples regarding scope of the PN, and
- dealing with IT general controls (ITGCs) in an SME audit environment; and
- examples need to be more innovative and not merely focus on straightforward circumstances to ensure they are useful in practice.
The Institute also calls for better coordination between the ISAs and the PN because as paragraph 4 of the PN states, the PN does not contain commentary on all the requirements in the ISAs and reading it should not be seen as an alternative to reading the relevant ISAs in their entirety.
Ultimately this means that SME auditors, inspectors, and software providers would still have to follow over 1,000 pages of the full ISAs and have regard to another 64 pages of the PN.
The response also draws attention to the fact that only nine ISAs are referenced in detail in the PN which could result in inconsistent interpretations and confusion when practitioners are performing SME audits. It would be more helpful for regulators also if there were better cross-referencing as to where requirements are not relevant or where requirements are scalable for SME audits in the form of a mapping document. This would remove the need for practitioners to review the entire series of ISAs when performing SME audits
For audit cold file reviews and tailored training sessions explaining more about various topics like AML, Audit, FRS 102, please send a mail to john@jmcc.ie.
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:
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. | Nov 16, 2025 | Blog, News
Section 392 Companies Act 2014, requires auditors to file a notice with the Registrar of Companies when they form the opinion that a company has failed to keep adequate accounting records. The form used to make such a filing is called a H4. The average number of H4 reports filed with the CRO in the last 6 years is 4 per year.
Unfortunately, the latest CRO Annual Report, that for 2024, does not publish the statistics for the numbers of H4s filed in prior years. All it gives is the numbers filed for 2024 itself, but in 2020 and prior years the CRO report names the companies for which H4s were filed, but it has since discontinued that practice.
The numbers of H4s filed in recent years is as follows:
| Year |
No. of H4 Reports |
Year |
No. of H4 Reports |
| 2024 |
5 |
2021 |
0 |
| 2023 |
3 |
2020 |
7 |
| 2022 |
4 |
2019 |
5 |
In recent memory the best known H4, has to be the first one that was filed in 2019 which was for the Cumann Peile na hEireann, (otherwise known as the Football Association of Ireland). It was filed in April 2019 and over five years later, the investigation by the Corporate Enforcement Agency (CEA) into the situation at the FAI is still ongoing at the time of writing.
Auditors who fail to file such a note face a Category 3 penalty which is either up to six months in prison or a fine of up to €5,000 or both.
For audit cold file reviews and tailored training sessions explaining more about various topics like AML, Audit, FRS 102, please send a mail to john@jmcc.ie.
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:
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.
