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D18205 1 (2017-12-08)

handle is hein.gao/gaobadubg0001 and id is 1 raw text is: GAO U.S. GOVERNMENT ACCOUNTABILITY OFFICE 441 G St. N.W. Washington, DC 20548 December 8, 2017 Mr. Ken Siong Technical Director International Ethics Standards Board for Accountants 529 Fifth Avenue, 6th Floor New York, NY 10017 GAO's Response to the International Ethics Standards Board for Accountants' September 2017 Exposure Draft, Proposed Revisions to the Code Pertaining to the Offering and Accepting of Inducements Dear Mr. Siong: This letter provides GAO's response to the exposure draft, Proposed Revisions to the Code Pertaining to the Offering and Accepting of Inducements. GAO promulgates generally accepted government auditing standards (GAGAS) in the United States. GAGAS provides a framework for conducting high-quality audits of government awards with competence, integrity, objectivity, and independence. Our comments reflect the importance we place on reinforcing the values promoted in both the Code of Ethics for Professional Accountants (the Code) and GAGAS. We support the International Ethics Standards Board for Accountants' (IESBA) efforts to strengthen the provisions in the Code related to inducements to assist accountants in better dealing with the offering and accepting of inducements while complying with the fundamental principles. In particular, as detailed in our response to question 1, we support IESBA's proposed general approach for dealing inducements, but we believe that the proposed standard could benefit from additional application guidance. Specific Comments Proposed Section 250 1. Do respondents support the proposals in Section 250? In particular, do respondents support the proposed guidance to determine whether there is an intent to improperly influence behavior, and how it is articulated in the proposals? We support IESBA's proposed general approach for dealing with inducements, including a) requiring the accountant to understand and comply with relevant laws and regulations; b) prohibiting the accountant from offering or accepting inducements if there is actual or perceived intent to improperly influence the behavior of the recipient; and c) requiring the accountant to apply the conceptual framework to identify, evaluate, and address any threats to compliance in the absence of actual or perceived intent to improperly influence behavior, unless the inducement is trivial or inconsequential. Page 1

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