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PCAOB ramp up enforcement against auditors

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Enforcement by the Public Company Accounting Oversight Board against auditors in 2024 is off to its fastest start in recent years, according to a new report. 

The report, released last week by the Brattle Group, found that under PCAOB chair Erica Williams’ leadership, the PCAOB has already brought more actions — 34 actions against 45 respondents — in the first six months of this year than each year under its previous leadership in 2018–2021.

In comparison, through June of last year, the PCAOB brought seven enforcement matters involving nine respondents (three individuals and six firms). Twenty of the 34 actions (59%) brought by the PCAOB during the first half of 2024 involved U.S. respondents (12 individuals and 15 firms). In the 14 actions involving non-U.S. respondents in the first half of 2024, eight individual respondents and 10 firms were charged. Approximately 30% of PCAOB actions disclosed in the first half of 2024 involved respondents associated with the six largest global networks. More than half of the actions involving firm respondents in the first half of 2024 alleged violations related to firms’ systems of quality control.

In contrast, SEC activity through the first half of 2024 is at its lowest levels in recent years. The SEC initiated three actions in the first half of 2024 involving four respondents (two individuals and two firms). In comparison, in the first half of 2018, the year with the highest H1 activity in the analysis’s sample, the SEC initiated 13 actions involving 17 respondents (nine individuals and eight firms). Neither of the two SEC actions involving firm respondents alleged violations related to the firms’ systems of quality control.

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The report attributes the low level of enforcement activity to the SEC awaiting the outcome of a Supreme Court decision involving the use of administrative law judges, who typically preside over cases instead of the overcrowded courts in order to speed cases. Ultimately, the Supreme Court curtailed the SEC’s ability to use the in-house judges and gave defendants the right to bring the case to a federal jury.

“The low levels of SEC enforcement activity in the first half of 2024 may be due, in part, to uncertainties related to the constitutionality of the SEC’s in-house ALJs while the agency awaited the U.S. Supreme Court’s decision in the SEC v Jarkesy matter,” said the report. “For example, on April 29, 2024, the SEC agreed to stay an in-house proceeding against a partner at accounting firm Marcum LLP, postponing the proceeding until 30 days after the Supreme Court issued its decision in Jarkesy.”

The PCAOB imposed penalties of nearly $35 million in the first half of 2024, more than the combined penalties imposed by the SEC and PCAOB during all of 2023 and three of the four years under the SEC and PCAOB’s prior administrations. In comparison, the PCAOB imposed a then-record $20 million during all of 2023, up from its previous annual high of $11 million in 2022. The $35 million in penalties in the first half of 2024 was driven by one mega-settlement of $25 million with KPMG Netherlands in April.

That represented the largest penalty in PCAOB history and was more than three times greater than the regulator’s prior record of $8 million imposed on a firm in 2016.

“Even setting aside the $25 million settlement, penalties in 2024 are outpacing 2023,” said the report. “Monetary penalties were imposed on respondents in more than 95% of actions initiated in H1 2024.”

Five firm respondents settled for $1 million or more, while four firms were required to engage an independent consultant. The PCAOB took four firm respondents’ cooperation into consideration when determining sanctions.

The SEC imposed monetary penalties of $14 million in the two actions that were finalized in the first half 2024. Despite finalizing only two actions in the first half of 2024, penalties in the first half of 2024 are greater than the $11.5 million imposed by the SEC in all of 2023 and three of the four full years under the SEC’s prior administration.

The SEC imposed severe nonmonetary penalties in both actions it settled in the first half of 2024. In one settlement, the SEC required a firm respondent to retain an independent consultant. In the second action, both the firm (BF Borgers) and individual respondents were permanently barred.

“PCAOB enforcement in 2024 is off to its fastest start in the agency’s history, bringing 34 actions against 45 respondents and imposing a record $35 million in penalties by the end of June,” said Brattle principal Alison Forman, who authored the report with associate Adam Karageorge, in a statement. “And the SEC, despite settling only two actions in the first half of the year, has already imposed higher penalties on auditors so far in 2024 than in all of 2023.”

The report also includes a discussion of how developments in the first half of 2024 – including the Supreme Court’s decision in SEC v. Jarkesy and amendments to PCAOB Rule 3502 governing contributory liability — could profoundly impact enforcement activity against auditors moving forward.

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Accounting

AI-Driven Automation and Continuous Accounting Frameworks

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The accounting profession is undergoing a fundamental structural transition as enterprise finance departments shift from periodic month-end closes toward automated continuous accounting models. By integrating specialized machine learning algorithms directly into enterprise resource planning (ERP) platforms, chief accounting officers are transforming financial reporting from a retrospective exercise into a real-time operational asset.

The Shift from Periodic Close to Continuous Financial Reporting
Traditional accounting workflows heavily relied on manual data reconciliation, spreadsheet calculations, and multi-week closing cycles at the end of each fiscal period. In contrast, continuous accounting frameworks utilize automated software agents to process, validate, and post transactional data in real time as business activities occur.

Automated bank reconciliation tools cross-reference incoming bank feeds, invoice records, and purchase orders automatically. By resolving transactional variances instantly throughout the month, corporate accounting teams eliminate the traditional workload spikes associated with quarterly and annual closes.

Machine Learning in Audit Trails and Anomaly Detection
Advanced natural language processing (NLP) and machine learning tools are redefining internal audit and financial control environments. Automated systems analyze 100% of general ledger entries, identifying anomalous transactions, duplicate payments, and unauthorized journal entries in real time.

Rather than relying on random statistical sampling, corporate internal auditors can focus their attention on high-risk flags automatically surfaced by algorithmic monitoring platforms. This continuous risk assessment strengthens internal controls over financial reporting (ICFR) and significantly reduces fraud risk.

Evolving Roles for Accounting Professionals
As routine data entry and manual reconciliation tasks become fully automated, the skill set required for accounting professionals is shifting toward data analysis, system design, and strategic business advisory.
– Systems Governance: Accountants are increasingly responsible for monitoring algorithmic accuracy and managing data integration pipelines.
– Business Partnership: Finance professionals leverage real-time financial dashboards to advise operational leaders on margin management and working capital allocation.
– Regulatory Compliance Management: Accounting teams utilize automated platforms to ensure compliance with dynamic tax codes and international accounting standards.

Core Implementation Recommendations
1. Deploy Automated Reconciliation Tools: Integrate continuous transaction processing modules into existing enterprise ERP architectures.
2. Establish Algorithmic Governance Controls: Implement strict internal testing protocols to ensure automated accounting rules comply with GAAP/IFRS standards.
3. Reskill Accounting Teams: Invest in training finance staff on data analytics, workflow automation, and predictive financial modeling.

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Accounting

Global ESG Reporting Standards and Double Materiality Compliance

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Corporate accounting departments face expanding reporting expectations as international sustainability disclosure standards achieve regulatory enforcement across major global jurisdictions. Chief Accounting Officers (CAOs) and corporate controllers are establishing rigorous internal accounting controls to treat Environmental, Social, and Governance (ESG) metrics with the same data precision, auditability, and governance as traditional financial statements.

Regulatory Harmonization Under Global Sustainability Frameworks
The implementation of standardized sustainability reporting frameworks—notably rules established by international sustainability accounting boards—has created unified expectations for public and large private enterprises. Corporations must report standardized metrics covering greenhouse gas emissions (Scope 1, 2, and material Scope 3), energy utilization, workforce demographics, and supply chain governance.

In Europe and other participating international jurisdictions, double materiality principles are mandatory. Under double materiality, organizations must report both how external sustainability risks impact corporate financial performance, and how internal corporate operations affect surrounding environmental and social structures.

Integrating Sustainability Metrics into Core ERP Systems
To provide auditable non-financial data, enterprise organizations are integrating specialized carbon accounting and ESG management platforms directly into core ERP systems. Automated data collectors capture energy utility invoices, logistics fuel consumption metrics, and vendor compliance records in real time.

Establishing automated, traceable data pipelines ensures that non-financial reporting is supported by clear audit trails. This structured approach allows external financial auditors to provide reasonable assurance on sustainability disclosures during annual corporate reporting cycles.

Financial Impacts and Capital Market Disclosure
Accurate ESG reporting directly influences corporate cost of capital and institutional credit ratings. Commercial lenders and institutional asset managers systematically incorporate sustainability metrics into risk pricing models. Companies that demonstrate transparent, verifiable progress in operational energy efficiency and climate risk mitigation benefit from expanded access to green bond markets and lower debt pricing.

Action Steps for Accounting Leadership
1. Implement Double Materiality Frameworks: Conduct comprehensive assessments to identify material financial and operational sustainability metrics.
2. Build Auditable Non-Financial Data Pipelines: Automate ESG data collection within core accounting software to ensure data integrity.
3. Align Sustainability with Annual Financial Filings: Prepare non-financial disclosures concurrently with financial statements to satisfy regulatory audit expectations.

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Accounting

Modernizing Internal Controls: Machine Learning and Continuous Monitoring in Auditing

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Internal audit departments and corporate risk managers are modernizing internal control frameworks by shifting from periodic sampling techniques to continuous monitoring and machine learning analytics. As operational data volumes increase across enterprise organizations, automated control testing ensures financial integrity, prevents corporate fraud, and streamlines annual audit engagements.

The Limitation of Periodic Audit Sampling
Historically, internal and external auditors evaluated internal controls by reviewing random samples of financial transactions—often analyzing less than five percent of total ledger entries. In complex enterprise environments, periodic sampling methods carry inherent risks of overlooking localized financial misstatements, unauthorized disbursements, or operational control breakdowns.

In 2026, progressive internal audit functions are utilizing automated continuous monitoring platforms that evaluate one hundred percent of financial transactions in real time. Continuous control auditing systems continuously monitor general ledger entries, procurement approvals, and expense reimbursements across all operating subsidiaries.

AI-Powered Fraud Detection and Anomaly Identification
Machine learning models trained on historical corporate financial data excel at identifying subtle transactional anomalies that indicate potential fraud or operational error. Automated systems instantly flag duplicate invoice payments, unapproved vendor creation, unusual journal entry timing, and unauthorized override of authority thresholds.

When an anomaly is detected, the automated auditing platform generates an instant risk alert, allowing internal audit teams to investigate root causes immediately. Early detection prevents minor operational errors from escalating into material weaknesses in financial reporting.

Streamlining External Audit Preparation
Continuous internal control monitoring delivers significant benefits during annual external financial audits. External audit firms can review continuous audit logs and automated control testing documentation, reducing the time required for manual field testing.

This integrated approach lowers overall audit compliance fees, reduces administrative burdens on corporate accounting staff, and provides senior management and audit committees with real-time visibility into the organization’s overall risk profile.

Core Implementation Guidelines
1. Transition to 100% Data Testing: Replace legacy sampling methods with automated continuous audit monitoring systems.
2. Deploy Anomaly Detection Algorithms: Implement machine learning models to identify unauthorized transactions and operational control overrides.
3. Align Internal and External Audit Workflows: Coordinate continuous control testing protocols with external auditors to optimize annual compliance cycles.

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