Regulatory Enforcement and Sanctions Bill [HL]

My Lords, the noble Baroness has just said that it is not correct to say that the regulator is investigator, prosecutor, judge, jury and sentencer, but is she not wrong? Is not the whole structure here based on the fact that the regulator imposes the penalty? The penalty stands unless and until the defendant—the alleged wrongdoer—appeals but, as we shall discover a little later, the defendant has to pay up and also to prove his innocence before the appeal tribunal. Therefore, the position is the same as if the regulator imposes the penalty. I also ask the noble Lord, Lord Borrie, to reflect on this very carefully. The citizen or business is in the same position as someone who has been found guilty by the magistrates’ court or Crown Court and then has a right of appeal. That is a very serious position to be in.