SEC Comment Letter 0000000000-23-009963 to MOBILE TELESYSTEMS PUBLIC JOINT STOCK Co (CIK 0001115837)
MOBILE TELESYSTEMS PUBLIC JOINT STOCK Co (CIK 0001115837)
Date: Sept. 8, 2023 · CIK: 0001115837 · Accession: 0000000000-23-009963
AI Filing Summary & Sentiment
File numbers found in text: 001-15094
Letter
United States securities and exchange commission logo September 8, 2023 Andrey Kamenskiy Chief Financial Officer Mobile TeleSystems Public Joint Stock Company 4 Marksistskaya Street Moscow 109147 Russian Federation Re:Mobile TeleSystems Public Joint Stock Company Form 20-F for the Fiscal Year Ended December 31, 2022 Filed April 17, 2023 File No. 001-15094 Dear Andrey Kamenskiy: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Form 20-F for the Fiscal Year Ended December 31, 2022 Independent Auditor's Report, page F-3 1.We note that the audit report states that the Mobile TeleSystems PJSC and its subsidiaries (the “Group”) financial statements were audited in accordance with International Standards on Auditing. Please revise your filing to include an audit report that complies with Instruction 2 to Item 8.A.2 of Form 20-F, which indicates that the financial statements of the issuer must be audited in accordance with the Standards of the Public Company Accounting Oversight Board (“PCAOB”). In this regard, we note that on page 160 of your Form 20-F, you include the audit report on the internal control over financial reporting of the Group as of December 31, 2022, and that opinion also refers to an audit, in accordance with the standards of the PCAOB, on the consolidated financial statements of the Group for the year ended December 31, 2022. In closing, we remind you that the company and its management are responsible for the
FirstName LastNameAndrey Kamenskiy Comapany NameMobile TeleSystems Public Joint Stock Company September 8, 2023 Page 2 FirstName LastName Andrey Kamenskiy Mobile TeleSystems Public Joint Stock Company September 8, 2023 Page 2 accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. You may contact Joseph Kempf, Senior Staff Accountant, at 202-551-3352 or Robert Littlepage, Accountant Branch Chief, at 202-551-3361 with any questions. Sincerely, Division of Corporation Finance Office of Technology
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United States securities and exchange commission logo
September 8, 2023
Andrey Kamenskiy
Chief Financial Officer
Mobile TeleSystems Public Joint Stock Company
4 Marksistskaya Street
Moscow 109147 Russian Federation
Re:Mobile TeleSystems Public Joint Stock Company
Form 20-F for the Fiscal Year Ended December 31, 2022
Filed April 17, 2023
File No. 001-15094
Dear Andrey Kamenskiy:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment. In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.
Please respond to this comment within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments.
Form 20-F for the Fiscal Year Ended December 31, 2022
Independent Auditor's Report, page F-3
1.We note that the audit report states that the Mobile TeleSystems PJSC and its subsidiaries
(the “Group”) financial statements were audited in accordance with International
Standards on Auditing. Please revise your filing to include an audit report that complies
with Instruction 2 to Item 8.A.2 of Form 20-F, which indicates that the financial
statements of the issuer must be audited in accordance with the Standards of the Public
Company Accounting Oversight Board (“PCAOB”). In this regard, we note that on page
160 of your Form 20-F, you include the audit report on the internal control over financial
reporting of the Group as of December 31, 2022, and that opinion also refers to an audit,
in accordance with the standards of the PCAOB, on the consolidated financial statements
of the Group for the year ended December 31, 2022.
In closing, we remind you that the company and its management are responsible for the
FirstName LastNameAndrey Kamenskiy
Comapany NameMobile TeleSystems Public Joint Stock Company
September 8, 2023 Page 2
FirstName LastName
Andrey Kamenskiy
Mobile TeleSystems Public Joint Stock Company
September 8, 2023
Page 2
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
You may contact Joseph Kempf, Senior Staff Accountant, at 202-551-3352 or Robert
Littlepage, Accountant Branch Chief, at 202-551-3361 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology