The global financial industry will look different in the future. As governments rethink regulations and companies figure out new business models, the scramble is already on in New York (via Washington), London, and Europe (via Brussels) for which cities and countries will come out on top as global financial capitals.

Cities in Asia and the Middle East want some of this business, too, as do their national governments.

But as the Financial Times‘s special section on Dubai today shows, New York and Europe have one important legal and regulatory advantage over some ambitious but less-developed financial centers.

The paper reports that “the Dubai dream can end in prison. With default a criminal offence, many expatriates are taking the advice of lawyers to leave the country before creditors have them put behind bars. The legal threat extends to company directors.”

Nobody ever thought about this risk when things were going well.

In America and Europe, insolvency and bankruptcy are not criminal offenses (unless they come with fraud). 

America and Europe grew their capitalist economies based on the idea of a second chance. People and businesses alike can make terrible decisions with money that belonged to other people and, through bankruptcy, start over generally unencumbered by those obligations.

Entrepreneurial societies don’t have recourse to debtors’ prisons.

As Dubai learns from experience, though, reforms there could gradually erase our edge — so it’s good that we have time to think of what we need to fix, too.