The Russian Ministry of Finance, as the body responsible for regulating audit activities, has published an information letter clarifying the government's April decree on potential restrictions on foreign-controlled audit firms operating in Russia. The interpretation of the document raised questions in the audit community and among the largest clients of auditors, the state bank VTB publicly commented on it.
Lawyers interviewed by RBC at the end of April said that the decree imposing a ban on auditors' access to sanctions-sensitive information would not affect the leading firms operating in Russia, including the Big Four - KPMG, PricewaterhouseCoopers, Deloitte, Ernst & Young ". Most of the major auditors in the country are controlled by Russian legal entities and individuals, but work under foreign brands, being members of international partnerships. In fact, they operate on a franchise, lawyers pointed out.
However, the Ministry of Finance's clarification corrects this interpretation. The risk that the new regulation will restrict the access of any audit company to client information is still there, follows from the letter of the department. “In the case when an audit organization is a member of an international network of audit organizations, the compliance of this audit organization with the criteria established by Decree No. 622 is determined taking into account such membership and the organizational basis for the activities of the international network,” the letter says. The wordings “taking into account such membership” and “organizational bases of activity” are not explained in any way. RBC sent a request to the press service of the Ministry of Finance.
The department's letter emphasizes that even if the auditor cannot obtain information from the client that is not disclosed in accordance with government acts, he does not have to break off relations with the client: another audit organization that is free from these restrictions. This situation will not contradict the international audit standards adopted in Russia, the Ministry of Finance believes.