and IntroductionGoverning transnational corporate behaviour through traditional regulatory design is a challenging objective that has been canvassed in much academic literature. Difficulties arise as, inter alia, transnational corporations make extensive use of regulatory arbitrage and corporate structures in order to avoid or mitigate the reach of legal and regulatory governance. Moreover, international soft law standards that encourage multinational corporations to be more responsible are not always effective or enforceable. Against this context, we explore an emerging regulatory trend in corporate regulation that has the potential to overcome some of the perceived limitations in the modern regulatory governance of transnational corporate groups.There is an intensifying trend in adopting procedural regulatory strategies for corporations. This involves prescribing various control systems and processes that corporations have to institute, such as compelling them to develop due diligence requirements within their commercial operations. This trend is not entirely new, and fits within the regulation theory framework of 'new governance', 1 such as 'management-based regulation' 2 or 'meta-regulation'. 3 However the changes we
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