What Circular 230 expects
Section 10.22(b) presumes due diligence when a practitioner relies on another person’s work product, but only if the practitioner used reasonable care in engaging, supervising, training and evaluating that person. A documented review process is the evidence of that care.
Section 10.36 places a duty on anyone with principal authority for overseeing a firm’s practice to take reasonable steps to ensure the firm has procedures for compliance. An outsourcing review workflow is one of those procedures.

