We considered the nature of the syndicate and its control environment, and reviewed the syndicate’s documentation of their policies and procedures relating to fraud and compliance with laws and regulations. We also enquired of management, those charged with governance, internal audit, internal general counsel about their own identification and assessment of the risks of irregularities.We obtained an understanding of the legal and regulatory frameworks that the syndicate operates in, and identified the key laws and regulations that:
•had a direct effect on the determination of material amounts and disclosures in the annual report and accounts. These included the Insurance Accounts Directive (Lloyd’s Syndicate and Aggregate Accounts) Regulations 2008 and the Lloyd’s Syndicate Accounting Byelaw (no. 8 of 2005), the Lloyd’s Syndicate Accounts Instructions; and
•do not have a direct effect on the annual report and accounts but compliance with which may be fundamental to the syndicate’s ability to operate or to avoid a material penalty. These included the requirements of Solvency UK.
We discussed among the audit engagement team including relevant internal specialists such as actuarial and IT specialists regarding the opportunities and incentives that may exist within the organisation for fraud and how and where fraud might occur in the annual report and accounts.
As a result of performing the above, we identified the greatest potential for fraud or non-compliance with laws and regulations in the following area, and our procedures performed to address it are described below:
•Valuation of technical provisions includes assumptions requiring significant management judgement and involves complex calculations, and therefore there is potential for management bias. In response to these risks, we involved our actuarial specialists to develop independent estimates of the technical provisions.
In common with all audits under ISAs (UK), we are also required to perform specific procedures to respond to the risk of management override. In addressing the risk of fraud through management override of controls, we tested the appropriateness of journal entries and other adjustments; assessed whether the judgements made in making accounting estimates are indicative of a potential bias; and evaluated the business rationale of any significant transactions that are unusual or outside the normal course of business.
In addition to the above, our procedures to respond to the risks identified included the following:
•reviewing annual accounts disclosures by testing to supporting documentation to assess compliance with provisions of relevant laws and regulations described as having a direct effect on the annual report and accounts;
•performing analytical procedures to identify any unusual or unexpected relationships that may indicate risks of material misstatement due to fraud;
•enquiring of management, internal audit and in-house legal counsel concerning actual and potential litigation and claims, and instances of non-compliance with laws and regulations; and
reading minutes of meetings of those charged with governance and reviewing internal audit reports, and reviewing correspondence with Lloyd’s, the Prudential Regulation Authority (PRA), and the Financial Conduct Authority (FCA).
Report on other legal and regulatory requirements
Opinions on other matters prescribed by The Insurance Accounts Directive (Lloyd’s Syndicate and Aggregate Accounts) Regulations 2008 and the Lloyd’s Syndicate Accounts Instructions
In our opinion, based on the work undertaken in the course of the audit: