backOn March 12, 2025, the PCAOB announced a settled disciplinary order against PwC Singapore for failing to establish and implement appropriate policies and procedures over its Personal Independence Compliance Testing (PICT) process and to foster an appropriate ethical culture within its Independence Office. Specifically, the Board alleged that for over a nearly two-year period, personnel in the firm’s Independence Office developed and implemented various methods to understate the firm’s PICT exception rates, i.e., the rates at which firm personnel failed to properly or timely report their financial interests and relationships. The PCAOB found that the firm’s leadership was focused on achieving a targeted PICT exception rate, which combined with a lack of appropriate PICT-related policies and procedures and related controls, enabled this misconduct. As a result, on two separate occasions, the firm provided understated PICT exception rates to the PCAOB as part of its remediation of prior PCAOB inspection findings, and this overall misconduct was not discovered until after an internal investigation was conducted following the PCAOB’s inquiry into the matter.
Without admitting or denying the Board’s findings, the firm consented to the Order which (1) censured the firm; (2) imposed a $1.5 million civil money penalty; and (3) required the firm to undertake certain remedial measures to establish, revise, or supplement, as necessary, policies and procedures, including monitoring procedures, related to the firm’s independence processes. The Board highlighted the firm’s “extraordinary cooperation in this matter,” which included sharing the results of its internal investigation with the PCAOB and voluntarily instituting remedial measures, noting that it may have imposed a larger civil money penalty or additional sanctions absent this extraordinary cooperation.
The settled order is available here.