There are lots of differences. One key difference is that US compliance goals have something to do with transparency (due to the markets insistence), we can argue about how well this works in practice, but this is not always the goal on other countries compliance efforts

For example Dan Blum notes:
"...it is impossible comply with the Sarbanes-Oxley Act (SOX) and French law at the same time. Following up with some security people later, I discovered this was a relatively well known problem that has nothing to do with technology, but does touch on different culture's positions on privacy.

There are two issues - one has to do with the prequalification of auditors, but the big one concerns the SOX requirement to provide an anonymous line for whistleblowers who might reveal financial skulduggery. Such a rule might raise eyebrows in the U.S. where the stigma around infoming on your colleagues is relatively mild, the rules raises hackles in France, which has a huge cultural stigma against informers, perhaps dating back to the time of Vichy government."

http://identerati.blogspot.com/2005/10/global-regulations-conflicting.html

i was at a european financial conference last fall where i brought up various issues with the (in)ability of sox to identify/prevent corporate crime; this years conference was held last week and its theme was global risks and investor confidence, in part inspired by some of the sox discussions last year.

old posting mentioning conference and sox
http://www.garlic.com/~lynn/2006h.html#58 Sarbanes-Oxley

as well as some posts in thread here
https://financialcryptography.com/mt/archives/000797.html

i.e.
http://www.garlic.com/~lynn/aadsm25.htm#12 Sarbanes-Oxley is what you get when you don't do FC
http://www.garlic.com/~lynn/aadsm25.htm#13 Sarbanes-Oxley is what you get when you don't do FC
http://www.garlic.com/~lynn/aadsm25.htm#14 Sarbanes-Oxley is what you get when you don't do FC
http://www.garlic.com/~lynn/aadsm25.htm#15 Sarbanes-Oxley is what you get when you don't do FC

Study Finds Sarbanes-Oxley Benefits Business (but does it find that SOX is doing what it was originally intended to do?)
http://www.newsfactor.com/story.xhtml?story_id=103003D0UZ2P

a cross over postings mentioning sox
http://www.garlic.com/~lynn/2006u.html#22 AOS: The next big thing in data storage

and other recent items:
Cheney Expresses Doubts About Sarbanes-Oxley
http://www.informationweek.com/showArticle.jhtml?articleID=193500718
Democrat Says Sarbanes-Oxley Already Being Thinned
http://www.baselinemag.com/article2/0,1540,2050437,00.asp
NY leaders see city's financial position threatened
http://money.cnn.com/2006/11/01/markets/bc.financial.newyork.politicians.reut/
Sarbanes-Oxley overkill, bankers say
http://www.newsobserver.com/104/story/504970.html
Lights Dimming On The Sarbanes Oxley Act?
http://www.crn.com/showArticle.jhtml?articleID=193700543
Greenspan calls SarBox a nightmare
http://weblog.infoworld.com/techwatch/archives/008823.html