A United Kingdom (UK) government investigation has allowed a complaint to proceed that alleges top accounting firm PricewaterhouseCoopers (PwC) ignored payments to terrorists when it audited the Palestinian Authority (PA). Major donors, like the United States, United Kingdom, and World Bank, rely on such audits to ensure millions of taxpayer dollars are not diverted to fund terrorism and other human rights abuses abroad. The UK government decision follows an eighteen-month investigation responding to a December 2016 complaint filed by UK Lawyers for Israel (UKLFI) with the UK National Contact Point for the Organization for Economic Cooperation and Development (OECD) Guidelines for Multinational Enterprises. The OECD Guidelines for Multinational Enterprises (the Guidelines), first adopted in 1976, set principles for responsible business, including standards for human rights and bribery prevention. All forty-seven adhering countries are required to maintain a complaint mechanism, known as the National Contact Point (NCP), allowing for third-parties to allege Guideline violations by companies headquartered domestically. UKLFI filed the complaint against PwC with the UK’s NCP, which is a part of the UK’s Department of International Trade. UKLFI is a nonprofit formed in 2011 that employs advocacy, legal research, and campaigning to support Israel. Several years ago, UKLFI became concerned about the “Amended Palestinian Prisoners Law No. 19 (2004),” which it claims not only authorizes the PA to pay the salaries of terrorists in Israeli prisons, “but [holds] that the more serious the crime, the greater the rewards for the prisoners while serving their sentence and on their release.” Knowing that the PA receives aid from nations and international organizations around the world, UKLFI worried that taxpayer dollars meant to improve the Palestinians quality of life, were actually funding violence. Per the UK Minister of State for International Development, UK’s aid to the Palestinians “is subject to annual, independent financial audit.” UKLFI wanted to verify that these audits were comprehensive, accurate, and demonstrated that the PA was not misusing donations from the global community. Thus, the UKLFI reached out to PA donors and received “a letter of confirmation from a donor client that PwC had a role in managing and auditing PA’s accounts.” Further, “UKLFI also obtained evidence from several sources in the public domain which established PwC’s historical work with the PA.” However, when UKLFI approached PwC for access to files related to their audits of the PA, PwC declined, “citing concerns over issues of client confidentiality.” Without any further recourse, UKLFI filed its complaint with UK’s NCP stating, “Because of the unwillingness of PwC to subject its audit reports to public scrutiny, it is unclear whether the funds from donors who rely on PWC’s guidance are directly funding the incitement of terrorism, or whether such funds, given uncritically, are liberating other resources that the PA can devote to the incitement of terrorism.” UKLFI further alleged that by “failing to raise concerns about PA spending aid money on salaries for terrorists and on glorifying terrorism,” PwC breached Chapter II, III, and IV of the Guidelines. UKLFI asserted these violations infringed the human rights of victims of terror attacks, Palestinian citizens, and taxpayers in donor countries to the PA. In response, PwC claimed it was not required to examine potential payments to terrorists because it was outside the scope of its agreement with the PA. The NCP dismissed this argument, noting its “implication that PwC should not be held accountable to a standard that it was not aware of. However, the Guidelines exist to promote an overall standard of good practice.” While the NCP investigation does not reach any final conclusions as to whether PwC acted inconsistently with the Guidelines, international human rights lawyer Jacob Turner, co-author of the complaint and former lecturer at Oxford University, asserted the mere ruling that the allegations are material and could be substantiated “shows auditors…can’t just turn a blind eye to human rights abuses being committed by or facilitated by the entities which they are auditing.” The UK NCP will ask UKLFI and PwC if they are willing to engage in facilitated mediation to resolve UKLFI’s concerns. While UKLFI has publicly expressed willingness to participate in mediation, PwC has not indicated whether it intends to participate. If mediation is successful, the UK NCP will issue a Final Statement without determining whether PwC breached the Guidelines. If mediation does not occur or fails to resolve UKLFI’s grievances, the UK NCP will conduct a separate examination and issue a Final Statement as to whether PwC acted inconsistently with the Guidelines. As the Guidelines are technically non-binding, there is no formal penalty associated with the finding of a breach. Nevertheless, the NCP can recommend actions to the breaching company and the public relations effect of an alleged Guideline breach is often enough to force a company to change its behavior—as seen in 2014, when a mining company, after facing an NCP complaint, abandoned a project in the Congo which threatened a World Heritage Site.