Securities law in the European Union and the United States: Comparing apples and oranges or potayto, potahto?

The globalization of the securities markets and rapid technological advancement
have made international financial markets law an increasingly important area of
regulation, practice, and scholarly research. Yet more in­depth analysis of the
dif­ferences of financial markets law and securities law, in particular, remains
unex­plored to explicate for underlying reasons for divergence. This study contributes to the stream of literature comparing securities law in the EU and the U.S. The fin dings suggest that differences in securities law arise from differing investor bases and different levels of integration of capital markets. Prohibition on trading on inside information in the EU is more recent but more extensive whereas the U.S. approach is older and more limited in scope.