The regulatory approach to litigation funding in Europe and England and Wales is set to take a different path to the United States, following periods of uncertainty and multiple regulatory proposals. Reports from the Civil Justice Council and European Commission propose a series of light-touch regulatory measures, including disclosure obligations and appropriate financial regulation. While the European Commission did not make a formal recommendation, it emphasised the need to balance access to justice with the need to prevent abusive practices. This will be important as use of collective redress measures continues to increase in EU Member States. In the United States, individual states are expected to maintain a focus on matters such as funder registration, disclosure, and transparency. However, the prospect of federal regulation remains in play. Two legislative proposals have been put forward, although their enactment remains uncertain. Both would compel disclosure of funding agreements, with one proposal also focused on foreign involvement, including a prohibition on third-party funding by foreign states and sovereign wealth funds.