- investigators need approval from a prosecutor to move forward with investigations, and ultimately have to present their evidence in sales calls to their boss/peers. It’s a lot of red tape.
- prosecutors have bosses and reputations to uphold, they don’t want to take on risk.
- judges act as a procedural review for the prosecutor and watchdog for civil liberties
- the defense is red teaming the prosecutor and investigators for fraud etc
- the appeals court acts as a second level review for everyone + original judge
- it’s all public so journalists can poke around.
Here's a British one: https://en.wikipedia.org/wiki/Viceroy_Research
There were a _number_ of British and German ones involved in the whole Wirecard mess.
Hindenburg's probably the world's most prominent, but there's nothing about the model that inherently requires being in the US.