PEEC Non-Enforcement Policy

The Professional Ethics Executive Committee (PEEC) has agreed that it will not take enforcement action against a member who is a member of a group engagement team in cases where a foreign component auditor involved in the group audit is not in compliance with the AICPA Code of Professional Conduct (AICPA Code) provided the foreign component auditor at a minimum is in compliance with the IESBA Code of Professional Ethics for Accountants (IESBA Code) and the members of the group engagement team are in compliance with the AICPA Code of Professional Conduct. (See SAS on Special Considerations— Audits of Group Financial Statements (Including the Work of Component Auditors).

Furthermore, the PEEC will not take enforcement action against a member who is a member of a network firm in cases where another firm within that network that is located outside the United States (“foreign network firm”) is not in compliance with the AICPA Code provided the foreign network firm at a minimum is in compliance with the IESBA Code. (See ET section 92.28-.29 for definitions of network and network firm).

Adopted by the PEEC on August 20, 2010. ET section 91.02 1. was amended effective November 30, 2011 to adopt the above provisions.