The regulation of the legal profession in Europe is within the competency of the Member States. So far there has been no harmonization by European Union ("EU") legislation. While very few Member States, with regards to regulation of the legal profession, have choice of law rules, no such conflict rules exist at EU level. This means as a consequence that whenever a lawyer works cross-border he is subject to his home country regulatory rules and to the host country regulatory rules at the same time-a phenomenon referred to in Europe as "double deontology." This double deontology is specifically recognized in the lawyer-specific directives of 1977 on temporary crossborder services and that of 1998 on cross-border establishment. The double deontology is also recognized in the Council of Bars and Law Societies of Europe's ("CCBE") Code of Conduct.
Hans-Jurgen Hellwig, At the Intersection of Legal Ethics and Globalization: International Conflicts of Law in Lawyer Regulation, 27 Penn St. Int'l L. Rev. 395 (2008).