Codes of conduct have been adopted very broadly on both sides of the Atlantic in the last two decades. They have been introduced for both elected representatives and appointed officials. Though the accountability mechanism varies a good deal, elected politicians have preferred to retain a high degree of self-policing and enforcement.For some types of appointed officials who carry out specialized functions with exposure to particular, clearly identifiable, ethical risk, where the need for public trust and confidence is great, it is important but also relatively straighforward to develop clear-cut codes of practice, and these have emerged as detailed and vigorously enforced codes that either overlap with professional standards or are free-standing(as in the case of competition regulators). For generalist public servants, whether at a national or subnational level, the situation is different. The range of ethical risk to which civil servants are exposed is broader. It is less easy to be specific about the risks involved. This has implications for the relationship between a code and other disciplinary and penal mechanisms governing public servants. Moreover, because the motivations behind the production of codes, where they are used, tend to vary between countries and to echo contingent public concerns, so do their contents. Thus, some codes focus on issues of personal propriety, honesty, conflict of interest and postemployment, while others spread across broader concerns about governance that include constitutional or quasi-constitutional relationships, impartiality, efficiency, institutional repute, and service delivery. For both these reasons efforts to agree on transnational standards for public officials, wheater nationally or locally, are likely to be among the most difficult to make meaningful of the various exercises now in progress to establish common understandings of ethics regulation among liberal democracies.