Audit failures and limits of the findings
The FRC identified a lack of professional skepticism and described the breaches as "numerous and serious". Its findings covered a significant number of violations of key auditing standards across seven areas.
Those areas were understanding the entity, derecognition of assets, recoverability of trade debtors, recoverability of intercompany balances, revenue recognition, journals testing and going concern.
The regulator did not suggest that the breaches were intentional, dishonest, deliberate or reckless, and it did not assert that the financial statements were actually misstated. Both respondents cooperated throughout the investigation, as required, the FRC said.
Financial penalties and reprimands
The fines reflect a 30% reduction for admissions and early disposal of the case. According to the FRC's Final Settlement Decision Notice, the starting penalties were £200,000 for HW Fisher and £25,000 for Mott-Cowan.
Both also received published Severe Reprimands. In declarations applying to each respondent, the FRC said the 2020 audit report signed by Mott-Cowan on HW Fisher's behalf failed to meet the Relevant Requirements.
The business and the investigation
Liberty Commodities operated as a UK private limited company trading non-ferrous metals, semi-finished steel and steel-making raw materials. Most sales were conducted on a "back-to-back" basis. The FRC said its business model depended heavily on supply chain finance from Greensill Capital (UK) Limited and Wyelands Bank, which was also part of the GFG Alliance.
The FRC opened its investigation into HW Fisher's audit on February 10, 2022, after its Conduct Committee approved the probe on January 25, 2022. The investigation proceeded under the Audit Enforcement Procedure.
While the investigation was underway, Mott-Cowan voluntarily stopped practicing as an auditor at the end of 2025. The FRC said he would no longer act as a Responsible Individual or perform any audit work.
