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One of the key issues in the on-going overhaul of the global financial system is the structural reform of banking systems. Legislatures in different states, for example, the United States, France, Germany and the United Kingdom, have all taken measures to protect individual depositors’ assets against losses from risky bank activities. On 29 January 2014, the European Commission joined the transnational effort by publishing its own proposal on the subject. This contribution shows how the same economic goal is implemented through different approaches by legislatures across the globe. It also analyses how this legal diversity will affect the level playing field in the competition for banking services and the consistency of global financial regulation.

Volcker rule, ring-fencing or separation of bank activities – Comparison of structural reform acts around the world