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When submitting a Sentinel request, there are

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several key elements you must focus on. First make sure you 

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select the correct engaging party(s), this includes, any party

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who is: signing or otherwise bound to the engagement

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contract, paying or receiving any of the engagement fees, or

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has a role in defining the engagement scope or selecting 

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KPMG for the service. Choosing the engaging party(s) with the

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correct legal name and Sentinel family tree icon allows the

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system to guide requests through the appropriate independence

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evaluation process, so it’s important to perform due

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diligence, making sure you select the correct entities. If

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you cannot find an entity in Sentinel, you can add a new 

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entity, however before doing so make sure you’ve done a

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thorough search. It’s important to avoid creating duplicate

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entities in Sentinel because this could lead to requests not

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being routed to the correct Sentinel Lead Partner for

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review, potentially causing independence violations. Once

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you’ve selected the correct engaging party(s) within Sentinel,

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you can move onto the other key elements you need to focus

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on when completing a Sentinel request.

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Second, select the correct taxonomy code that fully represents all aspects of

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the proposed service. If there are various components to the

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service, you’ll need to select multiple taxonomy codes. To

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help evaluate service permissibility, you can access direct

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links near the taxonomy descriptions to independence

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guidance and engagement letter templates contained on the

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Independence Non-Audit Services Portal. Be mindful that if

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the wrong taxonomy code is selected, or the request is

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missing a relevant taxonomy code, you will be required to

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withdraw your Sentinel request and submit a new one with the

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correct taxonomy code, which may cause delays with the

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Sentinel review and approval process. So, as a best practice,

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if there is uncertainty around what codes are to be used for

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which services, reach out to your team leader for guidance.

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Sentinel requests that include SEC audit clients and

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affiliates or public interest entity audit clients and

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related entities are required to have an engagement contract,

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SOW, or equivalent attached in the request. The scope of

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service in the contract must match the taxonomy codes

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included in the request.

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Third, select any relevant “Other Services” checkboxes applicable 

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to the service. For example, select the “Technology Solution with 

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Client Access” checkbox when services include licensing, or providing 

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client access to KPMG or third party technology solutions. Technology

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solutions may include, but are not limited to, products,

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software as service engagement enablers with client access,

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Excel schedules, alliance partner applications or where we

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implement third party technology, as well as the use of

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survey tools. This does not apply to collaboration tools

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that are solely used to share or send information between

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KPMG and the client in order to perform the permissible service.

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Fourth, include a detailed description of the service.

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Make sure sufficient detail is provided so the

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reviewer has a clear understanding of the service, can make

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an informed assessment of its permissibility, determine its

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potential effects on independence, and can effectively

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communicate the scope of permissible services to the Audit

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Committee for pre-approval, where required. The description of

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the service in the Sentinel request should match the

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description in the draft engagement letter or statement of work.

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Ultimately the services that are performed and the

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applicable deliverables provided to the client as part of

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the engagement must also match the Sentinel description

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This is referred to as a three-way match. 

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Fifth, select the fee arrangement and enter the fee range.

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Under PCAOB Rule 3524, details of the fee structure are required to be

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communicated in writing to the Audit Committee when seeking

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pre-approval for tax services provided to SEC issuer audit

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clients and subsidiaries. Permissible fee structures include

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fixed or time-based arrangements. Certain fee arrangements

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are not permitted for engagements with SEC restricted

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entities, such as contingent fees. If the estimated fee range

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changes, this field should be updated and discussed with the

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Sentinel Lead Partner so that proper pre-approval can be

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obtained from the client’s Audit Committee, where required.

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The fee range should correspond to the fee estimate included

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in the engagement letter. The high end of the fee range

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should not exceed any fee limits included in the engagement

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contract or the amount of the fees approved by the Audit Committee.

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Sixth, document your conclusion of the 

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permissibility of the service in Sentinel. Document the

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rationale for why the service is permissible under the

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applicable independence standards and the threats and

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safeguards evaluation either within the text box in Sentinel

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or attach to your Sentinel request. It’s also important to

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consider IESBA’s new requirement and document use of the

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Advice and Recommendations exception, where applicable.

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For services that involve SEC audit clients and their affiliates,

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remember to attach a draft engagement letter,

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statement of work, or similar detail of the scope of services

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to be provided to the Sentinel request. Engagement letter

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templates for audit and attestation services are found on Alex.

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For non-audit services, professionals are encouraged

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to use the engagement letters on the Independence Non-Audit

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Services Portal when providing advisory services, or in the

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Engagement Contracting Tool for tax services to ensure

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services are appropriately scoped for SEC audit clients and

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their affiliates. After you submit your request, you’ll need

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to wait for a Sentinel Approval Number, often referred to as

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a SAN, before the client  can execute the engagement letter or

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you can provide any service to the client. For recurring,

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multi-year engagements, teams must submit a new Sentinel

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request before KPMG is engaged to provide services for each

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year’s engagement. For example, tax compliance services

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scoped for a three-year period would require a new Sentinel

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request each engagement year. Be mindful that each element

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of a Sentinel request is a piece of the puzzle. To see the

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full picture, every puzzle piece must be included. The

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information provided in each field is critical to how the

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service will be evaluated. Inaccurate or incomplete

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information can result in an incorrect conclusion and can

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expose the firm to numerous risks. If you have questions

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while completing the Sentinel request, click on the question

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mark icon for detailed guidance. The Sentinel Requestor User 

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Guide is also a great resource to reference.

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