@0xabad1dea the UK system is similar, and also includes an expiry date on having to disclose even relevant convictions except in a few extreme cases (most notably you can never work with children if you’ve been convicted of an offence against children, but I suspect some forms of fraud are similar).

@0xabad1dea so much of this comes down to the national psyche if that makes sense? The American system is one of punishment in which suffering is the point, and politicians are penalised for not being performatively cruel to criminals, while most European systems tend to be focused more on rehabilitation and helping people with whatever caused them to be in a situation where they’re committing crimes.