"Once part of the realm of the sovereign state, criminal policy has now become a competence of the European Union. The Lisbon Treaty will facilitate the design of arrangements that guarantee mutual recognition between member states’ criminal justice systems. Potentially affecting most aspects of domestic penal procedures, these new developments in European law take place in a domain where culturally distinct legal characteristics are deeply entrenched. In that respect, the promotion of enhanced police and judicial cooperation throughout the Union may be considered as a daunting task, but the existence of comparable institutional structures by which distinct and very different national penal systems are coordinated shows that it is possible. The Area of Freedom, Security, and Justice built within the Union can hardly be analyzed without regard to these extra-EU legal settings. For this reason, the aim of the research is to compare the new EU framework for police and judicial cooperation with the long established and highly integrated American criminal justice system on one hand, and with the Council of Europe instruments devised to establish minimum standards in relation to human rights throughout the European continent on the other hand. The comparison will bear upon the institutional arrangements which promote the definition of common standards in criminal and penal procedure, and the substance of these standards themselves, taking into account the historical background and the political values underlying each of these particular settings. Such a contextual approach should enable the specificity of the Area of Freedom, Security, and Justice to be understood and its sustainability assessed in the light of the experiences of Council of Europe and the US. This contextual comparison will enable the identification of potential sticking points or, alternatively, effective tools for overcoming the seemingly intractable conflicts between opposing penal cultures."