IT-Director.com: US approach to corporate governance looks:
The European Union (EU) proposals for improvement in corporate governance in the slipstream of Europe's own corporate scandals take much the same approach as deployed in the USA in its Sarbanes-Oxley Act, primarily through improvement in auditing and accounting standards, oversight and responsibilities. Perhaps, the key difference is that .as the EU has no power to legislate on criminal law, its proposals may not enshrine criminal sanctions for violations, as they do in the USA, though individual EU nation states could introduce criminal sanctions for violations...
The EU Commission is proposing, and, of course this is subject to approval by the EU member states, the establishment of US styled Public Accounting Oversight Boards in each country. Auditors would be required to register with these national boards as well as an EU wide audit regulatory committee with responsibility for the implementation and oversight of detailed measures in proposed legislation. Non-EU auditors who worked on audits of EU listed companies would be obliged to with the relevant National Accounting Oversight Board. They would not be subject to any EU or EU nation initiated supervisory or disciplinary procedures if they are subject to such procedures within their own country."