アメリカ型規制国家のグローバル化と制度的多様化 : 金融セクターと情報通信セクターの日英比較を事例に

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One of the most notable features over the past few decades has been the worldwide spread of American-style independent regulatory agencies. A closer look, however, indicates that the American model has become diversified through the domestic institutional context across countries and sectors. This paper examines this complex phenomenon, the global spread of American IRAs with substantial cross-national and cross-sectoral diversity. Much recent political analysis argues that the spread is due to a mechanism of policy diffusion whereby policy decisions in a given country are systematically constrained by prior choices made in other countries.I show in this paper that this interpretation exaggerates the extent of interdependency of decision-making among countries and ignores international structural and domestic institutional factors. To overcome these difficulties, I develop an analytical framework that considers the relationships between international structural forces such as techno-economic and ideational factors on the one hand and domestic institutional factors including national policy style and path-dependency on the other. The central argument of this paper is that the spread of IRAs can be best explained by a combination of international structural forces (techno-economic and ideational) and domestic institutions.I mainly proceed via a case study methodology in comparing two sectors (communications and financial services) across two countries (Britain and Japan). The two sectors are frequently treated as representative cases in the policy diffusion literature. Britain and Japan are held to represent paradigmatic cases of different ‘varieties of capitalism’. Moreover, the American IRAs, especially the Federal Communications Commission and the Securities and Exchange Commission, are frequently referred to as a model in the policy debate in both countries. Thus these cases can be examined as a crucial experiment against policy diffusion and a cross-national and cross-sectoral comparison.These case studies demonstrate that while ongoing convergence on the American model is due to international structural forces and their consequential uncertainty about the existing policy paradigm, national and sectoral differences with respect to the extent of regulatory changes depend largely on domestic institutions. The mechanism of policy diffusion played, at best, a minor role in these processes, except in the case of establishing Ofcom where ECs new set of directives provided the basic timescale.

アメリカ型規制国家のグローバル化と制度的多様化 : 金融セクターと情報通信セクターの日英比較を事例に

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