The process of procedure.

(From Financial Director)

Byline: Robert Bruce, a leading commentator on accountancy issues.

When it comes to arguments over the value or iniquity of Sarbanes-Oxley, there is only one point to bear in mind above all. It's the culture, stupid.

It is no wonder that people in the UK are frustrated with the implementation of Sarbanes-Oxley legislation. Audience members at a conference held in London recently - featuring a panoply of US lawyers, regulators and chief accounting officers - could only listen in amazement. If anyone ever wanted a stark example of how very different, both culturally and operationally, UK and US business is, this conference was it.

The biggest difference was starkly laid out; in essence, the idea that US business adores process. And when things go wrong, the only solution is more process.

Process is, you see, demonstrable, but it doesn't stop failures such as Enron. It may make it harder, simply because there is more process, which is supposedly there to protect things from escaping scrutiny. But ego-driven fraudsters know ways around it.

It is also about American culture, where accountants are the process people - the beancounters. That is what American accountancy is for. Any serious business advisory services are provided by lawyers, and this is the fundamental difference between US practice and UK practice. If anything - though continental Europeans would be horrified at the mere suggestion - the US law-dominated business model is much closer culturally to the continental European business system, which likewise prefers legal process to principle-based clarity.