Title: A View Across the Atlantic: The Arc and Architecture of Private Enforcement Regimes in the United States and Europe
Abstract: The United States and Europe have traditionally taken very different approaches to the regulation of harmful conduct. European nations have relied almost entirely on the public enforcement of laws, whereas the United States has relied on a mix of public and private actors. In the United States, private rights of action have played a central role deterring illegal conduct - and, in fact, provided greater deterrence than public enforcers in some areas of law. They have also allowed injured parties to obtain compensation. Despite their very different histories, the private enforcement systems in the United States and Europe are showing signs of convergence today.
Publication Year: 2015
Publication Date: 2015-01-01
Language: en
Type: article
Indexed In: ['crossref']
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