of the US federal states, which is not the same thing as an international agreement. Within the
European Union, EC Directives may have a more drastic effect, since they may force national
governments to alter their specific national laws with a view to European harmonisation. Conversely,
it must be noted that a number of other initiatives to harmonise international legislation have not
succeeded. Perhaps the best example would be the ongoing difficulties in harmonising bankruptcy
laws in the major states of the European Union, in spite of efforts extending over some years.