Failure to file Form APs in a timely manner is a violation of PCAOB Rule 3211, “Auditor Reporting of Certain Audit Participants.”
In its sanctions, announced Oct. 4, the PCAOB said audit firm Yarel + Partners received a $35,000 civil money penalty and censure, and the following three audit firms received a $20,000 civil penalty and censure: Shanghai Perfect CPA Partnership; James Pai; and Liebman Goldberg & Hymowitz.
The firms — without admitting or denying the findings—consented to the PCAOB’s orders and disciplinary actions. Each firm also consented to undertake remedial measures to establish policies and procedures directed toward ensuring future compliance with PCAOB reporting requirements.
“All four firms have since filed the Form APs in question, but only after the PCAOB took action,” the PCAOB said.
The PCAOB said it discovered the firms’ violations during a sweep, in which it was collecting information about potential violations from several firms simultaneously. The sanctions follow an announcement that PCAOB Board Chair Erica Williams made in July that PCAOB would be conducting sweeps as part of its overall effort to strengthen enforcement.
“Investors and the public rely on Form AP disclosures to understand exactly who has a hand in the audits of public companies,” Williams said. “Timely disclosure is critical for transparency and accountability in our capital markets, and the PCAOB will be vigilant in enforcing disclosure rules.” 
Jaclyn Jaeger is a contributing editor at Compliance Chief 360° and a freelance business writer based in Manchester, New Hampshire.