全球化为各国提供了前所未有的机遇,但也蕴藏着巨大的风险。全球化下的金融市场具备了市场国际化、交易手段信息化、机构大型化等特征,这给金融监管带来了更大的挑战。果不其然,如今金融危机的蔓延让现行金融监管体制的弊端更显著的暴露出来。本文指出通过分析美日英三国金融监管体制的发展,我们可以看出,金融监管已经朝着统一化、混业监管、内外监管结合、合规性与风险监管配合的新模式发展。而我国在面临危机时,更应当以此为契机,完善法律体系,改进监管方式,保障中小投资者利益。 Globalization has provided unprecedented opportunities for all countries, but it also poses enormous risks. The financial market under globalization possesses such features as internationalization of markets, informatization of trading means and large-scale institutions, which bring more challenges to financial supervision. Sure enough, nowadays the spread of the financial crisis has exposed the disadvantages of the current financial regulatory system more prominently. This paper points out that by analyzing the development of the financial supervision system in the United States, Japan and Britain, we can see that the financial supervision and control have been moving toward a new model of harmonization, mixed regulation, internal and external regulation, compliance and risk supervision. In the face of crisis, our country should take this as an opportunity to improve the legal system, improve the regulatory approach and protect the interests of small and medium-sized investors.