Oleksandr V. Manzhai, Kharkiv National University of Internal Aﬀairs, Ukraine
The current study provides a comparative analysis of the special investigation activity systems in the world using the example of Germany, Great Britain, Peoples’ Republic of China, Russia, Saudi Arabia, USA and Ukraine. By means of synthesis and analysis the structure of the special investigation activity system has been formulated and its elements have been studied based on definite examples. Patterns which were applied during the analysis of the legislation of every country have been defined, and terminology has been selected in order to conduct a research. The division of special investigation activity systems into American, European, Muslim, Socialistic and Traditional ones has been proposed. The differences between national legislation with regard to the time of conducting special investigation activity, the degree of its integration into the criminal process and its transparency in respect of society have been formulated. The main trends observed at the present time concerning development of special investigation activity, in particular, the placing of special investigation activity in unclassified normative-legal acts and special investigative measures resulting from new, high technology have been defined. This study is the one of the first to attempt to systematically research special investigation activity systems through the use of comparative methodology.