SEC v. BDO China Dahua CPA Co., Ltd. and four other China-based audit firms (2014)

Judgment entered

Checked against the primary document on October 2, 2026. The library's summary, tags and figures for this record were compared with the regulator's own document by an AI model (Claude) following written instructions, with sampled and disputed records read a second time. No lawyer has reviewed them. A checked record can still contain errors, and checked does not mean endorsed. See how we check records or report a correction.

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In January 2014 an SEC administrative law judge found that five China-based accounting firms willfully violated Sarbanes-Oxley Section 106 by refusing to give the SEC audit work papers. Four firms were barred from practising before the Commission for six months and one was censured; in March 2015 the Commission recorded that the initial decision had become final as to the censured firm after the other four settled.

The record

Structured fields for this action, as recorded in our case library.
Agency	SEC
Release number	3-14872
Date filed	2014-01-22
Date resolved	2015-03-20
Court	SEC administrative law judge
Status	judgment
Asset class	equities, fx
Venue	NYSE, Nasdaq, OTC
Criminal parallel	No
Defendants	BDO China Dahua CPA Co., Ltd. (entity) ; Ernst & Young Hua Ming LLP (entity) ; KPMG Huazhen (Special General Partnership) (entity) ; Deloitte Touche Tohmatsu Certified Public Accountants Ltd. (entity) ; PricewaterhouseCoopers Zhong Tian CPAs Limited (entity)
Techniques

What was ordered

Civil penalty: —
Disgorgement: —
Prejudgment interest: —
Total relief: —
Alleged gain: —

A dash means the release did not state a figure we could extract, not that the figure is zero. Penalty and disgorgement are stored separately so aggregates across the library do not double-count the same dollars.

What is alleged to have happened

The decision, issued on January 22, 2014, concerns Rule 102(e)(1)(iii) proceedings against the China affiliates of the Big Four firms and BDO's Chinese firm.

On March 20, 2015 the Commission granted the Division's motion to withdraw its petition for review as to BDO China Dahua, so the censure became final, noting settlements with the other four. The record showed the matter as dismissed, listed no respondents, and tagged it as insider trading and as a Ponzi scheme.

No technique tag is applied. The only mention of a Ponzi scheme is a witness's job description; the case concerns refusal to produce audit records, not any trading or investment scheme.

Timeline

2014-01-22 Initial decision

Primary documents

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The linked release is a work of the United States government and is not subject to copyright. Our summary and narrative above are our own writing.

Record added September 10, 2026. submit a correction.