If the answer to the first question is confirmative, the appropriate accounting firm should be obligated to guard state secrets, and should not provide the appropriate working papers to any other organisation or individual, including the PCAOB. Even in the accounting firm itself, all control measures should be taken to limit strictly the scope of access. If the answer to the second question is also confirmative, the appropriate working papers must be kept in the PRC and may not be taken out of the PRC without the prior approval of the competent authorities.

　　On the other hand, will the business cooperation pattern between domestic and overseas accounting firms lead to an illegal exit of archives? It is learned that an overseas, say Hong Kong based?, accounting firm with a Chinese office that provides auditing services for Chinese companies listed in the U.S. would often ask its PRC Mainland office to conduct most of the basic auditing procedures.[⑨] After the latter finishes the basic auditing work, it would transmit the conclusive auditing working papers to the Hong Kong accounting firm in an electronic form via the Internet for the latter to finish the subsequent procedures on this basis. It can be seen that at least part of the auditing working papers created by the domestic accounting firm are provided to an overseas accounting firm by IT means, and these working papers are in fact already “going abroad”。 For archives “owned by the state” or “whose preservation is of value to the state and society” involving state secrets, does this business cooperation pattern breach the applicable provisions of the Archives Law?

　　The applicable laws and regulations do not provide specifically for this. If the answer is “Yes”， the domestic accounting firm might be faced with the risk of being punished by the archives authorities.

　　III.　Risk of certain provisions of the auditing services agreement not being accepted by the China Securities Regulatory Commission （CSRC）