In recent years, law enforcement efforts have become increasingly global in nature. In many areas of mutual concern, such as drug trafficking and money laundering, law enforcement officials in different countries are working cooperatively to investigate and prosecute criminals. Over the years, constitutional guarantees contained in the fifth and sixth amendments have evolved into three fundamental tests that must be met by the prosecution in order to obtain a confession: voluntariness test, Miranda test, and right to counsel test. The analysis of constitutional guarantees indicates the same type of conduct that renders a statement taken within the United States involuntary and inadmissible under the fifth amendment also renders a statement taken outside the United States involuntary and inadmissible. 39 references