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Author	Prof Dan W Puchniak
Organisation/Institution	Singapore Management University, School of Law
Country	SINGAPORE
Panel	Corporate Law and Governance
Title	From Brussels to Bangkok: Strategic Adaptation of the CSDDD in a Multipolar Corporate Governance Order
Abstract	Geopolitics has always influenced corporate law, but it has now become a first-order force in corporate governance as the Anglo-American-cum-global order unravels under intensifying geopolitical rivalry. Major powers — the United States, the European Union, and China — are advancing sharply divergent views of corporate purpose and the corporation’s role in society. The expectation of global convergence that once guided debates in corporate law has therefore given way to regionalization, where competing regulatory hubs promote rival corporate governance models and contest their reach. States caught between these paradigms increasingly pursue selective alignment that maximizes domestic political and economic advantage. Thailand’s recent experience illustrates this logic with exceptional clarity. In 2024–25, Thailand produced the draft due diligence law modeled directly on the EU’s Corporate Sustainability Due Diligence Directive, marking the first such attempt to transpose the CSDDD beyond the EU. As political uncertainty within Europe slowed the CSDDD, Thai officials questioned the logic of advancing an instrument whose future within the EU itself had become unsettled. The narrative shifted from “EU alignment” to “OECD readiness,” recasting mandatory due diligence as part of Thailand’s long-term accession ambitions rather than an externally imposed European standard. This reframing reduced political sensitivity and aligned the initiative with national strategic goals, revealing a pragmatic motivation to advance the OECD accession bid rather than adopt the EU vision of corporate purpose. If adopted, a bold effort by the EU to extend its Brussels-Effect influence could produce an emerging “Bangkok Effect”: a potential force multiplier that would extend the Thai CSDDD-style regime beyond the EU CSDDD’s narrowed scope. Thailand’s experience shows how corporate governance norms now travel through geopolitical competition rather than convergence. It also demonstrates that regionalization does not produce uniform adoption but strategic adaptation, through which states position themselves within an increasingly fractured corporate governance landscape.
Biography	Dan W. Puchniak is the Yong Pung How Professor at the Yong Pung How School of Law (YPHSL) – Singapore Management University, Director of the SMU Centre for Commercial Law in Asia, Inaugural Director of the Asian Corporate Law Forum, and a Research Member of the European Corporate Governance Institute (ECGI). He is widely recognised as a leading scholar of comparative corporate law and governance in Asia. His scholarship is published in leading journals, profiled in The Economist and The Japan Times, and cited by Singapore’s apex court. Honours include the 2023 ECGI Cleary Gottlieb Law Prize and the 2025 YPHSL Most Outstanding Legal Studies Teacher Award. He has held visiting appointments and delivered invited lectures at leading universities worldwide, including Cambridge, Columbia, Harvard, Oxford, Stanford, the University of Chicago, and the University of Tokyo. Before joining SMU, he was a tenured faculty member at the National University of Singapore Faculty of Law, where he held senior leadership roles and received multiple university level teaching awards. Before entering academia, he practised as a corporate and commercial litigator at a leading Canadian law firm.