Britain and the United States are increasingly matching one another stride for stride when it comes to supervision of the financial markets.  Today, the meme was copying - Britain has announced a qui tam whistleblower program that may work like the one rolled out by the SEC.  Earlier this year, it was about improving a flawed model; sick of being subjected to American deferred prosecution agreements, Britain came up with its own DPA scheme - and actually passed a law and went through notice and comment before doing so.  And at times in the past, the model has been harmonization through a deal, which was the case for the first Basel capital adequacy accord, which only developed after the US and UK concluded a tentative arrangement on bank reserves that threatened to shut the rest of the world out of those then dominant financial markets.

These different approaches - copying, improving, negotiating - are distinctions that matter; but the consistent transmission of American rules into British financial markets is pretty interesting, given that we used to be talking about how Sarbanes-Oxley had made America distinctively bad, and Britain distinctively attractive, to public issuers.

Administrative Law, Finance, Financial Institutions, White Collar Crime | Bookmark

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