Noting ambiguities and inconsistencies in Article 44:

• Paragraph 2 is unclear about who the ban on statutory audits applies to, so AmCham proposes a clearer wording to include both the audited entity and its affiliates as well as the audit firm and its affiliates,
• Paragraph 3 could impose stricter limits on non-public interest entities than on public interest entities; AmCham suggests a revision to clarify that exceptions apply if the audit firm has ensured audit independence.