"A Comparative Analysis of Corporate Fraud: Book Four" examines
corporate fraud in the United Kingdom compared with that of two
civil law neighbouring countries, France and Germany, as well as
the United States. The objective of the study is to discover how
fraud occurs, how the two different legal systems treat fraud,
contributing factors, and if recommendations were made to
authorities in an attempt to combat this illegal activity.
The UK can learn much from the French legal system and the way
France prosecutes corporations. Germany's Criminal Code is equally
comprehensive in its prescriptive definitions of fraud, especially
corporate fraud. Although the UK is striving for a general law
against fraud, the UK Fraud Offence Bill is very inadequate,
lacking detailed solutions. The UK has become entrenched in
upholding legal privilege, bowing to intense lobbying by the legal
profession. And the use of electronic evidence, vital in
prosecuting modern corporate fraud, remains overlooked.
The attitude toward corporate fraud in the UK remains
laissez-faire. By analysing corporate fraud in the US, France, and
Germany, author Sally Ramage highlights examples that the UK can
take from these countries that combat corporate fraud without
derogation of established international human rights.
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