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 international disclosure rules varied widely, raising the possibility that standards would be accepted on paper but ignored in practice. EU companies complained that standards were costly and confusing: “The standards have been criticized by businesses of all sizes for making accounts unreadable and irrelevant,” the Financial Times reported in March 2006. 229 In addition, the bo ard’s funding remained uncertain. The “big four” accounting firms continued to provide a third of funding, raising charges of undue influence, while other contributions were ad hoc.

Political realities suggested that gradual partial harmonization of standards and practices over a period of years was as much as could be expected. Whether such harmonization would reduce or increase hidden risks to investors remained to be seen.

Disclosing International Infectious Disease Outbreaks to Protect Public Health

From the mid-nineteenth century on, nations sought to create international practices to control the spread of infectious disease. International surveillance – the rapid reporting of disease outbreaks – was early recognized as a key to preventing deaths and illnesses. After several devastating cholera epidemics in the early 1800s, many nations negotiated international sanitary conventions that sought to harmonize variable national surveillance and quarantine laws. Since 1951, the International Health Regulations of the World Health Organization (WHO) have governed international surveillance of infectious diseases among member countries. An arm of the United Nations, the WHO is governed by a World Health Assembly composed of representatives of the WHO member governments. International Health Regulations require member governments to inform the WHO about cases of specified infectious diseases within set time periods. Traditionally, national governments have controlled the flow of information on which disease surveillance is based. Regulations also specify public health activities at ports and airports and set procedures for trade and travel restrictions, including limits on those restrictions. Their stated purpose is to minimize the international spread of disease with minimal interference with trade and travel. 230

By the 1970s, however, the WHO surveillance system was moribund. Only plague, cholera, and yellow fever were subject to international reporting rules and member states routinely violated even those reporting obligations. In practice, member governments’ incentives to protect national reputation and economic stability often outweighed incentives to join in international efforts to report disease outbreaks. At the same time, vaccines and antibiotics minimized some common infectious diseases in the United States and Europe, easing political pressure for effective surveillance. 231

But in the 1980s, the AIDS epidemic as well as the spread of other infectious diseases highlighted the failure of existing international regulations and reawakened international interest in more effective surveillance. In the United States, the national Institute of Medicine identified fifty-four infectious diseases that were on the rise owing to a combination of increased travel and trade, germs’ adaptability, and a lack of public health measures. 232

In 1995, the World Health Assembly directed the World Health Organization to revise the failed government-centered surveillance rules. But reaching agreement on new surveillance rules proved to be a slow process. New International Health Regulations were not adopted until 2005. 233 Meanwhile, the WHO cooperated with private groups to create informal networks to share information. The Global Outbreak Alert and