The massive Siemens bribery scandal has made US-style internal investigations the new model for Europe. But there is significant German and Europe-wide resistance to this model, as Michael D Goldhaber reports

On 15 November, 2006, more than 200 policemen descended on the Munich headquarters of German technology giant Siemens and the homes and offices of 30 Siemens executives around Germany to comb the premises for incriminating documents. It was one of Europe’s dreaded ‘dawn raids’, a term that bears little relation to the time of day but usually denotes the start of a tiresome ballet between the government and a company suspected of wrongdoing. In the traditional European model of prosecution, corporations stonewall and fight to the bitter end.