This thesis is the study of the role and regulation of the external audit in the UK and US. It argues that the current audit model is fundamentally flawed, which has a negative impact on the quality of financial audits. This research contributes to the debate on external auditing by suggesting a free-standing legal re-conceptualization of the audit model, which aims to improve the quality of audits and reduce opportunity for accounting fraud. The research findings are drawn from qualitative analysis of legal and financial accounting sources. The thesis consists of three main themes. Firstly, it provides a comprehensive analysis of the regulatory framework for auditing by looking at why, how and by whom audit is regulated. Secondly, it analyses numerous flaws inherent in the current audit model. The focus throughout the thesis is on problems relating to auditors' independence, deficiencies in the spheres of legal, professional and social accountability of auditors, and excessive concentration of the audit market. Thirdly, following the analysis of various theoretical and international audit arrangements, the thesis suggests a new audit model. A key function in this model would be played by an external, public body - the Public Auditing Board, which would be in charge of appointment and remuneration of auditors carrying out audits in the public interest. It is submitted that moving audits to the public sector is desirable in order to introduce genuinely autonomous auditors, to provide better quality of audits and to restore public confidence in capital markets.