estations as required in SOX section 404 were not.
More generally, a broader contrast is often asserted between the U.S. ‘‘mandatory’’ regime in
SOX and the ‘‘comply or explain’’ regime in the EU, and it is true that most of the EU member state
implementations include ‘‘comply or explain’’ components. But so too does the U.S. (as discussed
in the prior section). The stark contrast often suggested is an overstatement at best.