The american system of law differs a great deal from the continental in that we

The american system of law differs a great deal from the continental in that we have almost no input limitations on our actions in exchange for requiring courts to decide conflict on outputs. The european system seeks heavy limitation on actions in order to minimize conflicts.

The american system is superior for the use of truth testing, since it is very difficult to regulate truthful speech going in, other than to test due diligence when conflict arises.

For this reason I would expect the continental (more restrictive because of high blame avoidance) and the russian (absurdly low trust) to be more resistant to the use of the common law to test the truthfulness of speech than under the anglo system.