PwC violated SEC Rule $2-02($b$)$ of Regulation S$-$X and PCAOB Rule $3525$ by engaging in improper professional conduct in violation of the independence rules on audit clients. This case is unique because the firm had mischaracterized certain nonaudit services as part of the audit engagement to skirt its ethical responsibilities under SEC and PCAOB rules. In $2014,$ PwC performed nonaudit services for an audit client concerning Governance Risk and Compliance $($GRC$)$ software. According to AAER No$.4084,$GRC systems are used by companies to coordinate and monitor controls over financial reporting, including employee access to critical financial functions.$$ The client $$intended to use the GRC software to generate information as part of the company$$s control environment and to provide data to assist personnel in forming conclusions regarding the effectiveness of internal controls related to financial information systems.$$ At the time the GRC system was being implemented, it was intended to be subject to the internal control over financial reporting audit procedures$\mathrm{.}1$Footnote $1$ As stated in AAER No$.4084,$ the SEC rules