RE: Them there sanctions !1 Jul 2023 11:21
Doesn’t this apply?
“However, we would offer the following points on some common scenarios:
Where a UK auditor is providing standardised material to members of a group, or their auditors, for the purpose of the audit of the UK group accounts, and the group includes a Russian subsidiary, then the service of providing this material would generally not be considered within scope of the ban. Meanwhile, where bespoke material is provided for the audit of the specific subsidiary, this may qualify as the provision of auditing services to a person connected with Russia.
Where a UK company that is consolidating group accounts receives an audit report for a Russian subsidiary from a local Russian auditor, then this is generally considered the receipt and not the delivery of a service. This generally would not be considered within scope of these export bans.
If the UK company or its auditor wished to undertake any activities beyond the receipt of the report, such as discussing its contents with the subsidiary or local auditor in Russia, then we suggest they take independent legal advice and consider whether a person connected with Russia (as defined in the Regulations) is a direct or indirect recipient of audit services as a part of that interaction”