The Full Court of the Federal Court has dismissed an appeal by former registered company auditor Reginald Lance Williams, upholding an earlier judgment and leaving in place a disciplinary decision cancelling his registration as a company auditor.
The Full Court upheld the decision of the primary judge, Justice Perry, who had previously dismissed Mr Williams' challenge to a 2018 disciplinary decision of the Companies Auditors Disciplinary Board (CADB) to cancel his registration as a company auditor.
Mr Williams was also ordered to pay the costs of the appeal.
The disciplinary proceedings arose from Mr Williams' audit of the LM Managed Performance Fund for the year ended 30 June 2012.
ASIC Commissioner Kate O'Rourke said the judgment reinforced the important responsibilities and high standards expected of registered company auditors.
‘Auditors play a critical role in maintaining confidence in Australia's financial reporting framework.
‘The Full Court’s decision reinforces that registered company auditors are ultimately responsible for the quality of audits conducted under their supervision and cannot outsource responsibility to other members of an audit team.
‘The judgment also sends a strong message about the important role specialist disciplinary bodies like the CADB play in maintaining professional standards and protecting the public,’ Commissioner O’Rourke said.
The Full Court affirmed the primary judge's conclusion that no legal or jurisdictional error had been established in the CADB's decision-making process.
It found Mr Williams was responsible for the audit engagement and that the deficiencies identified by the CADB justified disciplinary action.
In doing so, the Court affirmed the role of specialist disciplinary bodies such as the CADB in assessing professional conduct and compliance with auditing standards.
Background
Following an application by ASIC, the CADB cancelled Mr Williams' registration as a company auditor in December 2018 and ordered him to pay ASIC's costs fixed at $200,000.
The disciplinary findings arose from Mr Williams' audit of the LM Managed Performance Fund for the year ended 30 June 2012. The CADB found that Mr Williams had failed to carry out or perform adequately and properly the duties of an auditor in several respects.
On 18 June 2025, the Federal Court dismissed Mr Williams' application for judicial review of the CADB's decision (see 25-106MR Federal Court dismisses application by former auditor of LM Managed Performance Fund).
Mr Williams subsequently appealed that decision to the Full Court of the Federal Court.
The Full Court has now dismissed the appeal and upheld the judgment of the primary judge.
The Companies Auditors Disciplinary Board is an independent statutory body established under the ASIC Act. Its disciplinary responsibilities include providing an incentive for registered auditors to maintain high professional standards, protecting the public, and educating the profession through the exercise of its powers to cancel or suspend the registration of auditors.