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esbranson 2 days ago

Yes that's my claim, as defined in Mexican law since that's more like most countries' legal systems.

I don't know so my claim is weak, my Wikipedia articles on non-US legal systems is extremely slow going, and I have not written articles on this particular topic outside the US. :( The real basis of my claim is that most of the world would be expected to have judicial procedures for seizing assets more akin to our CAF. What the US considers reduced rights, like no jury trial, is just how things are elsewhere. (Ain't no one with a right to a jury trial anywhere in the world ever gonna choose a bench trial, it's that much of a difference.)

marcosdumay 2 days ago | parent [-]

The most prominent feature of the US asset forfeiture isn't that it's ruled by bench trial.

esbranson 2 days ago | parent [-]

Is it the standard of proof?

Preponderance (US), Balance of Probabilities (CA, UK, Ireland, SG, AU, NZ, PH, SA, NG), extinción de dominio (MX, CO, BR)?

marcosdumay 2 days ago | parent [-]

It is that the asset can be forfeit before a judicial decision. And as a second, that there is no requirement to involve the asset owner in a judicial proceeding.

Civil forfeiture is a hot topic all over the world. But the US has Executive forfeiture in practice.

esbranson a day ago | parent [-]

> in practice

One of the differences is that the US has PACER (Public Access to Court Electronic Records), that in practice we have a clue. Since the 80s. It adds up.