First the Bribery Act, now the Banking Reform Act reverses the burden of proof. What can companies do to ensure robust compliance, pre-empt liability, and gain a distinct competitive advantage?

Rob Mason, Partner, Forensic Risk Alliance, UK
Becky Stones, Partner, Forensic Risk Alliance, UK
Derek Patterson, Principal, Forensic Risk Alliance, UK
Toby Duthie, Partner, Forensic Risk Alliance, UK

Rob Mason, Becky Stones, Derek Patterson and Toby Duthie at Forensic Risk Alliance in London examine ‘reasonable steps’ companies can take to affirmatively evidence compliance as they face a broadening regulatory drive to reverse the ‘Burden of Proof’. In July this year , in response to the Banking Reform Act the Financial Conduct Authority (‘FCA’) and Prudential Regulatory Authority (‘PRA’) published a joint consultation paper on the proposed Senior Management Regime (‘SMR’), Certification Regime and Conduct Rules. While this regulatory focus is on the financial services sector, it touches on wider themes applicable to many sectors and, along with ever larger and often duplicative fines, is part of a wider US-led international enforcement trend.

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United Kingdom Risk Consultant October 2014 Vol. 8, No. 29, Autumn 2014

Rob Mason


Rob Mason prior to joining FRA, spent over 20 years in research, structuring and trading at leading American and European investment banks.

Becky Stones


Becky Stones is a recognized market leader in valuation, risk and regulatory control. She spent over 20 years at a leading European investment bank.

Derek Patterson


Derek Patterson has widespread experience both in forensic white collar regulatory engagements, and in Treasury and Internal Audit. Prior to FRA, he was Group Treasurer at EasyJet, and has worked in a variety of controller and internal audit roles at Ford of Europe, Ford Credit, and the British Airways Group.

Toby Duthie


Toby Duthie is one of the founding partners of FRA and has over 15 years of forensic white collar regulatory investigative experience, including in the UK, the USA and Switzerland. He has worked on many of the highest profile US and UK bribery prosecutions. Prior to FRA, he worked in the investment banking advisory division of a leading European investment bank.

Forensic Risk Alliance


FRA Founded in 1999, Forensic Risk Alliance (FRA) is a full service consulting firm specializing in Forensic Accounting, Financial Investigation, Litigation Support, and Electronic Discovery. FRA is comprised of forensic accountants, financial analysts, database & IT experts, and litigation support specialists. We have fluency in German, Chinese, French, Spanish, Italian, Portuguese, and English. FRA assists businesses and institutions to resolve complex and high risk financial, legal and regulatory challenges. We offer a variety of solutions that encompasses the complete e-discovery life cycle. We offer collection services, data culling, a custom review platform, jurisdictional processing and hosting, data privacy, and dedicated project management. From our offices in the United States and Europe we have serviced and supported clients in nearly every major jurisdiction across the globe. Recent projects have taken us to Canada, Israel, Germany, Switzerland, France, the Netherlands, the UK, the US, Spain, Denmark, Norway, Sweden, Belgium, the Philippines, Indonesia, Thailand, the PRC, Nigeria, Iraq, the UAE, Jordan, Brazil and Australia.

United Kingdom Risk Consultant October 2014 Vol. 8, No. 29, Autumn 2014

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