Former BDO auditor banned for 20 years for faking documents

Amanda Nightingale, a former BDO auditor, has been given a 20-year ban by the Financial Reporting Council (FRC) in respect of her conduct in her role as the senior manager on a number of audits undertaken by BDO LLP between 2015 and 2019.

As set out by the FRC in the Particulars of Fact and Acts of Misconduct, on numerous occasions between 2015 and 2019, the watchdog said the conduct of Nightingale fell “severely short of the standards expected of a member of the ICAEW and has brought discredit to herself, BDO LLP, and the accountancy profession”.

It judged that she:

• caused or permitted auditor’s reports to be issued without approval from the audit engagement partner, including by inserting electronic copies of the signature of the partners responsible for the relevant audits without their authorisation;
• inserted electronic copies of the signatures of the audit engagement partners in other documents, including company accounts which she then filed at Companies House, without their authorisation;
• created false documents, and falsified existing documents, including audit evidence; and
• deceived a number of audit engagement partners and audited entities.

According to the FRC, Nightingale acted with “sustained dishonesty” over a five year period in relation to a large number of audits. 

Although the audited entities involved were generally smaller, private companies, the dishonesty and scale of misconduct in this case was “extremely serious”. 

The Executive Counsel of the Financial Reporting Council (FRC) has now entered into a settlement agreement with Nightingale, under the terms of the Accountancy Scheme and imposed significant sanctions.

As part of the settlement, Nightingale has been excluded from the ICAEW and is not allowed to undertake any accountancy work for a period of 20 years. A statement has also been published issuing a Severe Reprimand. 

Additionally, Nightingale has paid a contribution of £10,000 towards executive counsel’s costs of the investigation, having taken into account her financial circumstances.

The FRC issued Proposed Formal Complaints (PFCs) under the Accountancy Scheme against BDO and two former audit engagement partners on 2 August 2024. 

The PFCs allege misconduct against those parties following the FRC’s wider investigation into how Nightingale’s misconduct was able to occur and endure over such a long period.

Since the misconduct, BDO has implemented significant changes to its systems and controls which are being closely monitored by the FRC’s Supervision function.

Jamie Symington, deputy executive counsel, said: “The failures in this case are wide ranging and extremely serious. By deliberately signing audit reports without the relevant audit engagement partners’ knowledge, Ms Nightingale’s conduct has risked severely undermining confidence in the audit profession and BDO.

“The sanctions imposed in this case, including a 20 year recommended period of exclusion from the ICAEW and a condition that she does not undertake accountancy work also for 20 years, serve both to protect the public and underscore the importance of professional accountants acting honestly and with integrity.”

Symington added: “The FRC will not hesitate to take robust action to uphold trust and confidence in the quality of audit and financial reporting, which relies on an environment of transparency and accountability to enable investors, business, users of financial reports and the public to have confidence in financial statements.”

A BDO spokesperson said: “Five years ago, our partners discovered that a senior employee in one of our regional offices was operating without proper authority, falsifying signatures on audit reports. On being confronted, the person left the firm before her impending dismissal for gross misconduct. We promptly self-reported to our regulators and conducted an extensive and in-depth investigation that was delivered to the Leadership Team and our regulators in February 2021.”