If you don't mind, I'll try my hand at answering that question.
With regard to the comparative aspect first, I think it is fair to say we are either equivalent or more restrained in our scope in terms of investigative hearing procedure.
The United States, of course, has the grand jury system, whereby a person could be compelled to testify in order to determine whether a criminal charge would be laid.
Australia has the equivalent of an investigative hearing system, which to some degree is similar to ours but in some respects is also different from ours. Their investigative hearing process is set out in their security intelligence legislation, but they have something equivalent to ours.
A major difference is in the United Kingdom. Mr. Piragoff mentioned that our investigative hearing process does not entail any criminal penalty relating to any offence at all. It's just to have someone come before the judge and answer questions posed to them by the crown. In the United Kingdom there is a specific offence of failing to disclose information about a possible terrorism offence, or for that matter even a past terrorism offence, to a police constable. Failure to provide that information is itself a criminal offence that's set out in an amendment to their Terrorism Act 2000. To that extent, it's fair to say that the United Kingdom goes even more strongly towards punishment and criminalization than we do.
I'm sorry; I forgot the first part of your question.