Last time I looked at this was a few years ago, but I don't think things have changed fundamentally.

1. In the trial of major crimes, the court is composed of 3 judges and 9 lay jurors. Unlike the US, where the trial judge gives instructions and the jury deliberates alone, the French judges and jurors deliberate and vote together. It requires 8 votes for conviction, i.e. all three judges plus a majority of the jurors.

2. As has been noted, the heart of the French system is the instruction preliminaire, the investigation carried out by an investigating magistrate, the juge d'instruction. He takes the initiative and can question whom he wants, including the accused. The prosecutor and defense counsel can provide input and suggest lines of inquiry, but the magistrate runs the show. It is his task to determine if a crime has been committed, if so by whom, and to report the case on for trial after developing all evidence both inculpatory and exculpatory. The instruction preliminaire is not a public proceeding.

3. The written record of the instruction preliminaire is available to the court and is used by the presiding judge as a guide to questioning.

4. There is no habeas corpus in France and no right to bail or to a speedy trial. The police can hold a suspect in garde a vue for several days after arrest. Once the magistrate commences the instruction, a suspect can be held until it concludes.

5. There is no privilege against self incrimination as we understand it either. The defendant may refuse to answer the magistrate's or the court's questions, but that refusal is noted and the adverse inference may be drawn. Indeed, the first order of business at the public trial is usually to question the accused, although not under oath.

6. There is no hearsay rule and no cross-examination as we understand it. Witnesses give narrative statements; they are questioned not by the prosecutor and defense, but by the presiding judge. Counsel for the parties may have questions asked through the court.

7. There is no restriction on character evidence. On the contrary, the first phase of the trial is devoted to developing a complete picture of the defendant's personality and background.

8. The principal, indeed the almost the only direct role of the trial counsel, is to conduct the closing argument after the court has taken testimony.

For a good recent accounts, see The Intersection of Two Systems: An American On Trial For An American Murder In The French Cour d'Assises, 2001 U. Ill. Law Rev. 791 and Anatomy of a French Murder Case, 45 Am. J. Comp. Law 527 (1997).