Capital markets regulation in the European Union and in the United States has progressively
converged in a variety of areas. Lawmakers in the two legal systems recognize the vital importance
of investor protection and transparency for the correct functioning of the financial markets and
have adopted legal instruments to increase market efficiency that are often based on common
grounds. Nevertheless, disclosure obligations on material corporate information continue to
show differences on either side of the Atlantic, and corporate compliance in that respect is
based on different rules for US and for EU companies.