In the United States you've got the series of different jurisdictions. You've got the federal and the state jurisdictions. So it varies enormously. The California system is that if a restitution order is made, then the state correction system--you've got two levels of the correctional system--tracks the payments and they take money off the wages or income of the prisoner.
I think the Justice for All Act--that's the federal act from 2004--is a very important model to look at because it actually provides legal aid for victims to sue and try to get restitution.
I also want to draw your attention to the National Crime Victims Center in the United States, which has set up seven preconditions for restitution to actually get paid. The ombudsman referred to some of these in her evidence. But basically if we want to see restitution paid you have to start right from the beginning. So when the person's charged you need to get some idea of what that person's worth is. You need to make sure the victim is aware of restitution. That means the police need to inform them. You have to enable them to request it in a written request--I lost $500, or $500,000, whatever it is. We certainly need to make sure that judges are following this. The State of Oregon, for instance, had a sentence--not a restitution sentence, but another sentence--vacated because the victim's right was not respected, and it went to the Supreme Court.
So we need to make sure that when judges are not obeying what's in the Criminal Code or the spirit of what's in the Criminal Code, it's respected. We need to change the Parole Act and so on. You have to do it the whole way through.