As if we needed reminding that things are different on either side of the Atlantic, two recent corporate governance events—one in the United States and one in the United Kingdom—demonstrate this starkly.
In the United Kingdom, the Business, Energy and Strategy (BEIS) Committee has recommended that the U.K. Corporate Governance Code be rewritten so that the Financial Reporting Council (FRC) can take enforcement action against non-executive directors. In contrast, the U.S. House Financial Services Committee has just passed the Financial CHOICE Act, also known as the “Death of Dodd-Frank,” which seeks to claw back the enforcement activities of the SEC.
