Sanctions against HW Fisher LLP and Simon Mott-Cowan
News types: Investigations
Published: 27 October 2026
This Press Notice concerns the outcome of an investigation into the relevant Statutory Audit Firm and Statutory Auditor. It does not make findings against any persons other than the relevant Statutory Audit Firm and Statutory Auditor* and it would not be fair to treat any part of this Press Notice as constituting or evidencing findings against any other persons or entities since they are not parties to the proceedings.
Executive Counsel of the Financial Reporting Council (“FRC”) has issued a Final Settlement Decision Notice under the Audit Enforcement Procedure and imposed sanctions against HW Fisher LLP (”HWF”), as Statutory Audit Firm, and Simon Mott-Cowan (”Mr Mott-Cowan”), as Statutory Auditor, in relation to the statutory audit of the financial statements of Liberty Commodities Limited (”LCL”) for the financial year ended 31 March 2020.
In relation to the areas investigated, there were breaches that were fundamental to HWF’s audit work, many of which involved a lack of professional skepticism. The breaches were numerous, and serious and pervaded the seven areas relevant to the breaches.
The following sanctions were imposed:
Against HWF:
- A financial sanction of £140,000 (this figure reflects a starting point of £200,000, which has been discounted for admissions and early disposal by 30%);
- A published statement in the form of a Severe Reprimand; and
- A declaration that the 2020 Audit Report signed on behalf of HWF did not satisfy the Relevant Requirements.
Against Mr Mott-Cowan:
- A financial sanction of £17,500 (this figure reflects a starting point of £25,000, which has been discounted for admissions and early disposal by 30%);
- A published statement in the form of a Severe Reprimand; and
- A declaration that the 2020 Audit Report signed by Mr Mott-Cowan did not satisfy the Relevant Requirements.
At the end of 2025 and during the course of the FRC’s investigation, Mr Mott-Cowan voluntarily ceased his audit practice. He will no longer be acting as a Responsible Individual or undertaking any audit work.
Background and summary of breaches
LCL operated as a UK incorporated private limited company dealing with physical trading, supply chain, and logistics management of non-ferrous metals, semi-finished steel, and raw materials required for steel making. LCL is part of the GFG Alliance (“GFG”), an unconsolidated group of companies, under common ownership, and operating in a number of industries, including the manufacture and trading of steel and aluminium, and renewable energy.
The majority of sales made by LCL were “back-to-back”, meaning that LCL would purchase materials from a supplier only when onward sale of the same goods to a customer had been agreed. The business model of LCL relied heavily on supply chain finance facilities provided by both Greensill Capital (UK) Limited (“Greensill”) and Wyelands Bank (“Wyelands”) to finance commodity trading transactions. Wyelands was also part of the GFG Alliance.
There were a significant number of breaches of key auditing standards in the following areas of the audit work investigated, namely: (i) understanding the entity, (ii) derecognition of assets; (iii) recoverability of trade debtors; (iv) recoverability of intercompany balances; (v) revenue recognition, (vi) journals testing; and (vii) going concern. There were failings by the Respondents to identify risks associated with LCL’s business model and a failure to understand, and to conduct adequate audit procedures on, the obligations imposed on LCL under the relevant finance agreements. The Respondents conducted the audit without a proper understanding of how the financial arrangements with Greensill and Wyelands operated which had significant ramifications for several aspects of the audit, including derecognition of assets and going concern.
While the breaches were numerous and serious, it is not suggested that they were intentional, dishonest, deliberate or reckless. Nor is it asserted that the Financial Statements were in fact misstated. The Respondents co-operated with the FRC’s investigation throughout, as required.
Andrew Twomey, FRC Acting Deputy Executive Counsel“This audit failed in its principal objective to obtain reasonable assurance about whether LCL’s financial statements as a whole were free from material misstatement. The issues stemmed from a pervasive and fundamental lack of professional skepticism by the auditors in the areas investigated. Serious and numerous breaches of standards were found in this case across multiple areas of work.
HW Fisher and Mr Mott-Cowan failed to comprehend and respond appropriately to obvious risks, including the risk of withdrawal of the Greensill financing facilities, despite the growing public scrutiny, as reported in the media at the time of the audit, on Greensill’s exposure to the GFG Alliance. The case highlights, in particular, the importance of auditors’ work in understanding the entity and its environment, and how failures in this area can undermine the ultimate performance of the audit as a whole.”