Scenario

The Tyco corporate scandal was discovered in 2002. After a mistrial, the Chairman and Chief Executive Dennis Kozlowski and former Chief Financial Officer Mark H Swartz were found guilty of the theft of more than US$150 million. They were convicted of more than 30 counts of fraud and sentenced to no less than eight years and four months and no more than 25 years in prison.

question

Critically compare and contrast the Tyco investigation, trial process and conviction in the United States (common law system) to how each stage would have been dealt with in Germany (civil law system) and Saudi Arabia (religious law system).