SEC Comment Letter 0000000000-23-000631 to AENZA S.A.A. (CIK 0001572621)
AENZA S.A.A. (CIK 0001572621)
Date: Jan. 20, 2023 · CIK: 0001572621 · Accession: 0000000000-23-000631
AI Filing Summary & Sentiment
File numbers found in text: 001-35991
Letter
United States securities and exchange commission logo January 20, 2023 Fredy Chalco VP of Corporate Finance AENZA S.A.A. Av. Petit Thouars 4957 Miraflores Lima 34, Peru Re:AENZA S.A.A. Form 20-F for the Fiscal Year Ended December 31, 2021 Filed May 16, 2022 File No. 001-35991 Dear Fredy Chalco : We have reviewed your December 15, 2022 response to our comment letter and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to the 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 the comment, we may have additional comments. Unless we note otherwise, our reference to the prior comment is to the comment in our December 1, 2022 letter. Form 20-F for the Fiscal Year Ended December 31, 2021 Report of Independent Registered Public Accounting Firm, page F-2 1.We have reviewed your response to our comment 1 and acknowledge our phone conversation with you and your former independent registered public accounting firm, Moore Assurance S.A.S. (“Moore”), on January 10, 2023. Please respond to the following: •Describe the nature of the relationship between the audit firms of Moore and Vizcarra y Asociados S.C.R.L. Moore Peru ("Moore Peru") as it pertains to the audit of your consolidated financial statements for the three years ended December 31, 2021 and underlying business reasons for structuring the audit in this manner. •Describe the nature and extent of supervision and direction by Moore to the Moore
FirstName LastNameFredy Chalco Comapany NameAENZA S.A.A. January 20, 2023 Page 2 FirstName LastName Fredy Chalco AENZA S.A.A. January 20, 2023 Page 2 Peru employees that participated in the audits of the consolidated financial statements for the three years ended December 31, 2021. As part of your response, please discuss the PCAOB Standards applied in performing the audit in this manner. •Describe how the employees and partners participating in the audits of your consolidated financial statements became employees of Moore Peru, and who was responsible for hiring of these employees. As part of your response, discuss where these partners and employees for your audit were sourced from and any business reasons for structuring the hiring in this manner. •Explain in further detail how you and Moore concluded that the performance of the audits in this manner, which included Moore Peru, an unregistered firm, playing a substantial role in the audit of your consolidated financial statements for the three years ended December 31, 2021, did not violate PCAOB Rule 2100. You may contact Babette Cooper at 202-551-3396 or Jennifer Monick at 202-551-3295 if you have any questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction cc: Juan Mendez
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United States securities and exchange commission logo
January 20, 2023
Fredy Chalco
VP of Corporate Finance
AENZA S.A.A.
Av. Petit Thouars 4957
Miraflores
Lima 34, Peru
Re:AENZA S.A.A.
Form 20-F for the Fiscal Year Ended December 31, 2021
Filed May 16, 2022
File No. 001-35991
Dear Fredy Chalco :
We have reviewed your December 15, 2022 response to our comment letter and have the
following comment. In our comment, we may ask you to provide us with information so we may
better understand your disclosure.
Please respond to the 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 the comment, we may have additional
comments. Unless we note otherwise, our reference to the prior comment is to the comment in
our December 1, 2022 letter.
Form 20-F for the Fiscal Year Ended December 31, 2021
Report of Independent Registered Public Accounting Firm, page F-2
1.We have reviewed your response to our comment 1 and acknowledge our phone
conversation with you and your former independent registered public accounting firm,
Moore Assurance S.A.S. (“Moore”), on January 10, 2023. Please respond to the
following:
•Describe the nature of the relationship between the audit firms of Moore and Vizcarra
y Asociados S.C.R.L. Moore Peru ("Moore Peru") as it pertains to the audit of your
consolidated financial statements for the three years ended December 31, 2021 and
underlying business reasons for structuring the audit in this manner.
•Describe the nature and extent of supervision and direction by Moore to the Moore
FirstName LastNameFredy Chalco
Comapany NameAENZA S.A.A.
January 20, 2023 Page 2
FirstName LastName
Fredy Chalco
AENZA S.A.A.
January 20, 2023
Page 2
Peru employees that participated in the audits of the consolidated financial statements
for the three years ended December 31, 2021. As part of your response, please
discuss the PCAOB Standards applied in performing the audit in this manner.
•Describe how the employees and partners participating in the audits of your
consolidated financial statements became employees of Moore Peru, and who was
responsible for hiring of these employees. As part of your response, discuss where
these partners and employees for your audit were sourced from and any business
reasons for structuring the hiring in this manner.
•Explain in further detail how you and Moore concluded that the performance of the
audits in this manner, which included Moore Peru, an unregistered firm, playing a
substantial role in the audit of your consolidated financial statements for the three
years ended December 31, 2021, did not violate PCAOB Rule 2100.
You may contact Babette Cooper at 202-551-3396 or Jennifer Monick at 202-551-3295 if
you have any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc: Juan Mendez