Is this different than the US's self-incrimination defense? I'm curious, because in the US the prosecution doesn't necessarily need you to say anything to make

Is this different than the US's self-incrimination defense? I'm curious, because in the US the prosecution doesn't necessarily need you to say anything to make a strong case against you. Just a lot of evidence pointing at you and you being unable or unwilling to defend yourself against it. Most defense attorneys view the 5th amendment as an armed grenade. By not saying anything it infers guilt. Saying too much can add to the case against you. Used wisely and you can work it in your favor. All of this is done without the use of passive surveillance. Just good detective work.