The Rules of Professional Conduct are intended to apply as well to all registrants,

The Rules of Professional Conduct are intended to apply as well to all registrants, whether or not engaged in the practice of public accounting, except where the wording indicates that the applicability is more limited. However, a registrant practicing outside the United States will not be subject to discipline for departing from any of the rules stated herein so long as his conduct is in accord with the rules of the organized accounting profession in the country in which he is practicing. However, where a registrant’s name is associated with financial statements in such a manner as to imply that he is acting as an independent certified public accountant and under circumstances that would entitle the reader to assume that United States practices were followed, he must comply with the requirement of all applicable rules.