Auditors’ Reactions to the Exposure Draft of SAS No. 54

The US Auditing Standards Board Statement on Auditing Standards (SAS) No. 54 concerns Illegal Acts by Clients. SAS No. 54 is discussed and its requirements are summarised. Written comments on a draft of SAS No. 54 from the auditing community have been analysed. Issues that were highlighted included lack of requisite skills, legal exposure, materiality threshold, responsibility, use of legal counsel, definition of illegal acts and communication with the audit committee. Opinions regarding possible consequences of SAS No. 54 came from both ends of the spectrum.