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In the past few years the US and the European Union have had to react to the accounting scandals of Enron, WorldCom and Parmalat. During this process the US has served as a role model for many provisions within the European Union. Several regulations of the Sarbanes-Oxley Act were adopted and the European Union implemented a central information system. The enforcement of legal duties is also influenced by the US model, resulting in civil liability claims gaining more importance. However, the strict criminal sanctions are – in light of the different legal cultures understandably – not adopted. In the future, the US and the EU should cooperate even more, before either passes important laws in this area unilaterally.

european company and financial law review

Creating Standards in a Global Financial Market – The Sarbanes-Oxley Act and other Activities: What Europeans and Americans could and should learn from each other –