In a January 2012 article, we reviewed the enforcement program
of the Public Company Accounting Oversight Board (the
"PCAOB" or "Board") over its initial decade,
following the Board's establishment under the Sarbanes-Oxley
Act of 2002 ("Sarbanes-Oxley").1 This article
updates that analysis by examining the PCAOB's enforcement
program in 2012, as reflected in Board proceedings made public last
year.
Our update focuses on PCAOB proceedings "made public"
last year, because the PCAOB remains subject to restrictions under
Sarbanes-Oxley that limit its ability to publicize enforcement
actions against registered public accounting firms or their
associated persons. Specifically, under Sarbanes-Oxley and the
Board's rules, the PCAOB is not authorized to make its
enforcement proceedings public until (1) the parties consent to a
public hearing,2 (2) the Board has imposed sanctions and
the time to file an appeal with the Securities and Exchange
Commission (the "SEC" or
