The paper examines events subsequent to the 1998 corpus juris proposals as the proto-criminal code. It examines the report by the Committee of Independent Experts, identifies themes within it, and revisits the reasons for the creation of UCLAF (Unite pour la Coordination de la Lutte Anti-Fraude), and the determination of its policies. It also discusses the recommendations of the Committee of Independent Experts on the issues of fraud and corruption in the context of an increasingly globalized system of financial regulation. Finally, it discusses the effort against fraud in the context of the ongoing dispute between the European Parliament, the European Commission, and the governments of the member States over the location of policymaking. The paper discusses three elements of a successful European system of fraud investigation and three practical steps toward such a system. It also identifies prerequisites for an effective cross-border investigative system into fraud. It concludes that sovereignty and human rights constitute the cloak behind which member States try to prevent effective cross-border investigation. References