The professional accountant during a time of uncertainty

An update for members on managing the implications of the war in Ukraine

Maggie McGhee, executive director – strategy and governance at ACCA

Our thoughts at this turbulent time are with our members, students and community in Ukraine as they face continued shocking and tragic events.

We oppose the Russian invasion; we believe in freedom of choice and the right to self-determination; and we wish to see a just and peaceful end to the war.

Ours is a global profession. It is united through a shared commitment to ethics. While ACCA members work in practice, with SMEs, in the public sector or in industry we have a shared belief in public value.

This means working in the public interest, promoting responsible and ethical business and supporting sustainable global economic performance – these are core to everything ACCA stands for and how we approach all our work.

A reminder about compliance

The war in Ukraine places the accountancy profession under increased pressure to assess risks to operations and ways of working.

Accountants are adept at risk management, but now extra vigilance is crucial, with difficult and complex decisions having to be made at pace.

Whether in industry, in practice or the public sector, accountants and finance professionals will face specific and complicated issues relating to their legal, ethical and professional obligations regarding anti-money laundering, sanctions and clients who may now become politically exposed persons. A full understanding of supply and value chains and the implications of sanctions are therefore essential.

As professional accountants we strive for the highest standards of ensuring ethical behaviour. Understanding and applying the law in the face of adverse conditions is a significant component in professionalism and business integrity. We see this as the baseline minimum for a professional accountant, where every member should aspire to go above and beyond.

Accountants may find themselves in charge of complex and apparently irresolvable issues. However, as qualified professionals, we are equipped with the skills and knowledge to approach these difficult situations, and recognise when to work with other professionals, such as lawyers and risk managers, to ensure that we fulfil our responsibilities to society and stay on top of potential threats, such as cyber-attacks and money laundering.

Each jurisdiction will have their own specific rules and regulations, which makes keeping up to date on these complex issues a challenge. We provide here reminders which we hope you, your teams and colleagues find helpful in these unprecedented times:

As an ACCA member, remind yourself of the ACCA Rulebook and ACCA’s Code of Ethics and conduct

This Code is binding on all our members and students, as well as any partner or director in an ACCA practice. Failure to comply may result in disciplinary actions.

The IESBA Code of Ethics and our own individual Code sets out for accountant to:

a) act in the public interest;

b) apply the fundamental principles, and applying in particular:

(i) Integrity at all times;
(ii) Objectivity in the exercise of their professional or business judgement;
(iii) Professional Competence and Due Care, including by maintaining and updating their professional knowledge and skills; and
(iv) Professional Behaviour, including the duty to comply with relevant laws and regulations and to avoid any conduct that might discredit the profession in any manner, whether directly or indirectly.

c) respond to non-compliance with laws and regulations in a timely manner.

Find out more

Check your relevant government department’s websites for any updates about sanctions, updates to tax, business law rules and regulations.

Governments will continue to update their sanctions lists.

It is important for accountants to understand the full scope and impact of any sanctions and how these may affect their business, clients and third-parties. You may also wish to seek legal advice in this regard to fully understand their scope.

Ensure you keep abreast with all developments including, but not limited to these, by bookmarking the relevant pages of government departments that deal with business laws, corporate governance codes, tax and international trade and all forms of cross-border transactions.
Money laundering compliance is also essential. Again, check your own government’s rules and regulations about procedures and processes as the increase in sanctions may result in an increase of money laundering activity with individuals and firms looking to find loopholes or inappropriate business solutions.
Report concerns. This is a legal obligation in many jurisdictions. Our website includes a comprehensive FAQ about our whistleblowing process.

While this helpline is for the UK only, the advice and guidance are still helpful in identifying suspicious activity, instances of non-compliance with the anti-money laundering regime, or potential involvement in money laundering or terrorist financing by ACCA members or firms.
Review or conduct a full risk assessment focusing on supply chains, payments, clients and third-parties. Knowing your clients, their operations, their supply chain connections and who they are making payments to and receiving payments from are vital as these are essential parts of a risk assessment.
Our report Rethinking Risk for the Future is a helpful resource.
Refer regularly to local and global regulators’ websites. Check their updates too as they will also be reviewing the situation and may provide updates which could be helpful.
Refer to the technical pages of the ACCA website for updates. We’ll be refreshing these pages as and when necessary.

Lastly, we want to raise a point about wellbeing – your own and your team’s. It’s important to talk to your colleagues about hurdles, barriers and frustrations, to check in on their wellbeing and ask about how they feel or think.

The uncertainty of the current situation is stressful. People faced with apparently impossible situations will need additional support. Teams may need to talk and connect more than before.

In this way you can ensure they understand the remit of their work, while also importantly connecting to check they’re coping, and discuss any concerns that they may have.

Communicating and collaborating are essential in these times, and accountancy professionals will be the ones asking a lot of questions to ensure the information flow is fluid and helpful for decision makers. Having trusted and candid conversations is an essential part of ensuring that accountants can discharge their obligations in a professional manner.