2025

MODULE in LEA 2

COMPARATIVE MODELS IN POLICING

By: Ethel June I. Fortu, RCrim

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TABLE OF CONTENT
CHAPTER I – Introduction to Comparative Models in Policing
Introduction
Basic Goals of Policing
Roles of Police
Different types of Policing
Concepts Relative to Comparative Policing
Types of Police System
Theories of Police Service
Concept of Police Service
Style of Policing
Policing Policy Models
Comparative Criminal Justice
International Crime
Comparative Research Method
Theories of Comparative Criminology
Types of Societies
Model Country for Comparative Policing
CHAPTER II – Different Types of Policing/Law Enforcement
Community Policing
Problem-Solving Policing
CompStat Policing
Intelligence-Led Policing
Evidence-Based Policing
Pulling Levers Policing
Hot Spot Policing
Third-Party Policing
CHAPTER III – The Effect of Globalization and the Multi-Cultural Policing
Globalization
Effects of Globalization
Effects of Globalization to Law Enforcement
Community Policing in Multi-Cultural Communities
The Canadian Context
CHAPTER IV – Transnational Crime

Transnational Crime
Organized Crime Group Typologies
Top 10 Criminal Organization
Forms of Transnational Organized Crime
Stages of Illegally Moving Migrants
Human Trafficking vs. Human Smuggling
Various Conceptions of Trafficking
Cybercrimes
Crimes that Permanently Target Computer Networks or Devices
Money Laundering
Environmental Crimes
Maritime Piracy
Terrorism

CHAPTER V – Extradition Treaty

Revised Phil. Extradition Law

CHAPTER VI – International Law Enforcement:

ASEANAPOL, EUROPOL and INTERPOL

ASEAN Chiefs of Police (ASEANAPOL)

European Police Office (EUROPOL)
International Association of Chiefs of Police
International Criminal Police Organization (INTERPOL)
INTERPOL NCB-Manila
UN Convention Against Transnational Crimes

CHAPTER I
 INTRODUCTION TO
COMPARATIVE POLICING

“Policing is one of the most important functions undertaken by every sovereign

government.”

 Comparative - an estimate of relative likeness or unlikeness of two objects or

event
-Denotes the degree or grade by which a person, thing, or other entity has
a property or quality greater or less
in extent than that of another.

 Policing - This is the practice for the maintenance of peace and order, law
enforcement and for the security of the community.
-It is the practice by the police officers for the maintenance of peace and order.

The development of police systems is driven by country’s socio-cultural background;

hence the differences exist between these systems from one country to another.
The act of comparing one police system with others according to differences and
similarities is simply referred to as "comparative policing”.

POLICE STRUCTURE: A Comparative Study of Policing Models

Dictionaries define “police” as the governmental department charged with the
regulation and control the affairs of the community. Chiefly the department established
to maintain order enforce the law, detect and prevent crime.

Basic Goals of Policing

Police are often entrusted with various functions relative to safety, peace, and order.
These functions are:
1. Enforcing Laws;
2. Preserving peace;
3. Preventing crimes;
4. Protecting civil rights and liberties; and
5. Providing services

Roles of Police
1. A watchman
2. A law enforcer
3. A service provider
Different Types in Policing
The police organization is rooted in the country’s the socio-cultural and historic
background.
Policing can be classified based on legitimacy or legal backing of the following police
functions:
 Policing by consent- refers to the legitimacy or acceptability of policing based on
the consensus or agreement of support that follows as a result of transparency on
powers and integrity, exercising powers, and accountability on the exercise of
powers. It is a concept rooted in the belief that the authority of the police derives
from the consent and cooperation of the public they serve.
 Policing by Law – means that police are responsible for maintaining public order
and safety, enforcing the law, and preventing, detecting and investigating criminal
activities. These functions are known as policing.

Policing is classified based on two dimensions:

A. Number of Forces to be commanded
  In a singular model, the police forces operate under a single commander.
 In the multiple coordinated models, the police forces have well-defined
territories of function which do not overlap with each other.
B. Types of Forces
 The coordinated centralized police force is highly organized and have
centralized command. However, if the police forces in the country do not
have a clear centralized command structure, it is called decentralized
command.

Concepts Relative to Comparative Policing

 Comparative – is an adjective or an adverb which denotes the degree or by which a
person or thing has a quality greater or lesser in extent than that of another.
 Comparative Research – is the act of scientific inquiry which employ comparative
analysis to have a better understanding of two or more phenomena and provide valid
reasons.
 Police – is the governmental department charged with the regulation and control the
affairs of the community. Chiefly the department established to maintain order enforce
the law, detect and prevent crime.
 Comparative Police System
 Process of outlining the similarities and differences of one police system to
another in order to discover insights in the field of international policing.
 It is the science and art of investigating and comparing the police system of
nations. It covers the study of police organizations, trainings, and methods of
policing of various nations.
 This study covers the comparison of selected police models and their
relation with Interpol and UN Bodies in the campaign against transnational
crimes.

TYPES OF POLICE SYSTEMS

1. Common Law Systems – Anglo-American Justice. It is a body of unwritten laws based
on legal precedents established by the court. It in influences the decision-making process
in unusual cases where the outcome cannot be determined based on existing statutes or
written rules of law.
The features of common law system include:
 There is not always a written constitution or codified laws.
 Judicial decisions are binding. The decision of the highest court can only be
overturned by that same court or through legislation.
 There is extensive freedom of contract because only a few provisions are implied
into the contract by law.
 Generally everything that is not expressively prohibited by law is permitted.
2. Civil Law Systems – also known as Continental Justice or Romano-Germanic Justice, is
a codified system of law which takes its origin from Roman Law. It is distinguished by a
strong inquisitorial system where the accused is granted minimal rights and the written
law is taken as gospel and subject to a little interpretation.
The feature of civil law system includes;
 A written constitution exist which is based on specific codes enshrining basic
rights and duties.
 Only legislative enactments are considered binding for all. There is a little scope
for judge-made law in civil, criminal and commercial courts which is based on
previous judicial decisions. Constitutional and administrative courts can nullify
laws and regulations.
 There are courts specific to the underlying codes:
constitutional court, administrative court, and civil court systems.
 There is less freedom in contract. Many provisions are implied into a contract by
law and parties cannot contract out of such provisions.
3. Socialist System – is distinguished by procedures designed rehabilitate the offender
which exists in some places in Africa and Asia.
The Socialist Law or the Soviet Law is a general type of legal system which has
been used in communist and formerly communist states. This law is based on the civil
law system, with major modification and additions from Marxist-Leninist ideology.
In the socialist system all production and distribution decisions are made by the
government. The individual relies on the state for everything from food to healthcare.
The government determines the output and pricing levels of these goods and services.
4. Islamic System - is based on the concept of natural justice or customary law or tribunal
traditions. Sharia is Islam’s legal system. It is derived from the Quran, Islam’s Holy
Book, as well as the Sunnah and Hadith – the deeds and saying of the Prophet
Muhammad.
The primary sources of Islamic Law are the Holy Book (The Quran), The Sunnah (the
traditions or known practices of the Prophet Muhammad), Ijma’ (Consensus), and Qiyas
(Analogy).

Theories of Police Service

1. Continental which maintain that police officers are servants of higher authorities. This
theory prevails in the continental countries like France, Italy, and Spain.
2. Home Rule which states that police officers are servants of the community or the
people. This is likewise the police services that prevails in the Philippines based on the
existing laws concepts and principle.

Concept of Police Service

1. Old Police Service states that the yardstick of police proficiency relies on the
number of arrests made.
2. Modern Police Service states that the yardstick of the police proficiency relies on
the absence of crime.

Style of Policing
1. Watchman Style- emphasizes maintaining order, usually found in communities,
with a declining industrial base, and a blue-collar, mixed ethnic/racial population.
2. Legalistic Style- emphasizes law enforcement and professionalism.
3. Service Style- Emphasizes the service functions of police works. Usually found in
suburban, middle-class communities where residents demand individual treatment.

Policing Policy Models

1. Crime Control Model
 This is based on the presumption that the repression of criminal behavior is the most
important aspect of police duty over individual freedom. Therefore, it should be
prioritized.
 This approach is rationalized in the assumption that inconvenience or harassment of
innocent people is justifiable because the police are fighting crime.

2. Due Process Model

 This is when due process is the primary object of the of policing.
 It focuses on just and fair justice system which does not infringe on constitutional rights.

Why do we compare systems and issues in criminal justice?

1. to benefit from the experience of others
2. to broaden our understanding of the different cultures and approaches to the
problems.
3. to help us deal with many transnational crime problems that plague our world
today.

Comparative Criminal Justice

 Comparative criminal justice is a subfield of the study of criminal justice which
deals with comparison of the different justice systems. Comparing criminal justice
systems can be done using descriptive, historical or political approach. When
comparing the different systems, the similarities and differences un structure,
goals, punishment and emphasis on rights as well as the history and political
structure are examined.

3 Basic Functions of Criminal Justice System

A criminal justice system has the following functions:
1. Policing or law enforcement which visible among the three functions.
 2. Adjudication or the court system which determines whether the suspect is guilty or
innocent and delivers justice based on ruling.
3. Corrections which handle the sentencing and the punishment for offenders of the
law.

International Criminal Justice

International criminal justice is the study and description of one country’s law,
criminal procedure or justice process.
It uses evaluation and investigation to build knowledge on the criminal justice if one
country which is relative to its culture or the institution itself.

International Criminal Law (ICL)

International criminal law (ICL) is relatively new and constantly developing branch of
public international law. ICL criminalizes the most serious violations of human rights and
international humanitarian law (IHL). In addition, it exposes perpetrator of such conduct
to criminal liability. ICL provides for criminal sanctions that apply to all perpetrators.
Criminal sanctions include those who are involved in planning and authorization of
criminal acts as well those directly commit crimes. As such, those at the highest political
and military can be held accountable for international crimes.

What is International Crime?

International crime is defined as crimes against the peace and security of mankind.
Examples of international crimes includes war crimes, crime of aggression, crime against
humanity, and genocide. Enumerated are different examples of international crime:
1. Aggression by one state against another using armed force inconsistent with
United Nation Chapter.
2. Threat of Aggression – is an act carried out against human being which has direct
effect to economics, infrastructure, peace and security of a country or state.
3. Genocide -is the intent to destroy, in whole or in part, a national, ethnical, racial or
religious group. The act that amount to genocide if committed in this context are:
a) Killings;
b) Causing serious bodily harm to individuals;
c) Inflicting conditions of life calculated to bring about its physical destruction,
are imposing measures intended to prevent birth; or
d) Forcibly transferring children of the group to another group.
4. Terrorism – which is the unlawful use of violence and intimidation against civilian
for political gains.

5. Drug Trafficking- is the crime of illegally distributing or transporting unlawful

controlled substances such as cocaine, marijuana, heroin, among others.
6. War Crimes -when grave breaches of treaty or customary rules of IHL are
committed. It is considered to be the most serious violation of IHL. Willful killing,
wanton destruction of private property, torture or inhumane treatment, willfully
causing great suffering or serious injury to body or health, unlawful deportation or
transfer, taking of hostages, recruitment and use of child soldiers, and willfully
depriving a person of the rights of fair and regular trial, all occurring in the context
of an armed conflict are considered as war crime.
7. Crime against humanity- includes systematic and widespread attacks against a
civilian population which lead to serious human rights violations. Crimes against
humanity include torture, murder, extermination, sexual violence, persecution, and
apartheid.

Comparative Research Method

Comparative research is usually carried out by the following:
1. The Safari method where the researcher visits another country or the
Collaborative method where the researcher communicates with a foreign
researcher.
2. Published Works tend to fall into three categories:
(a) Single-culture studies where the crime problem of a single foreign country is
discussed.
(b) Two-culture studies which is the most common type among the three
categories.
 (c) Comprehensive textbooks which covers three or more countries deals with the
examination of crime and its control in the comparative context. This method uses
a historical perspective as the phenomena being examined is perceived to be
developed under unique social, economic, and political structures.
3. Historical-comparative is also called historiography or holism. This method is
sometimes used as an alternative to quantitative and qualitative research methods.
Making it the most employed method among the three.
In historiography, there are at least eight ways to do history:
a) The Great Man Approach-people in positions of power deserve to lead because of
characteristics granted to them at birth, which ultimately help them become heroes. No
great man lives in vain. The history of thr world is but the biography of great men.

b) The Historical Forces Approach-utilizing the past to enhance understanding the

analysis within various disciplines.

c) The Crisis of Civilization Approach- attempts to reveal the diverse conditions and
problems of modernization through historical and geographical comparative research in
the present period in which traditional cultures in a strict sense no longer exist.

d) The Dialectic Approach- is the method of discussion that refers to coming up with
answers through the medium of the logical and reasonable discourse of arguments,
keeping in mind that no disrespectful arguments are made; it is a discussion between
different entities about their point of view.

e) The Evolutionary Approach- refers to a perspective that views institutions as products

of interactions within populations over time, where actors are boundedly rational and
operate under limited information.

f) The Geographic Factors Approach- relies on science and data to understand problems
and reveal solutions. A geographic approach considers how all factors are
interconnected, uniting data types by what they have in common—location.

g) The Conflict or "Who Won" Approach- approach conflict is an intrapersonal conflict

when a decision is to be made from two appealing choices. The choices are both positive
and equal in the eyes of the decision-maker. The solution comes in during movement to
one of the choices.
h) The Serendipity or Accidental Discovery Approach- happy discovery attributable
neither to luck nor skills but rather a combination of the two – serves as a critical
mechanism, fostering incremental advancements through the recombination of existing
ideas and observations.

On the other hand, in holism, which is a term that describes when a whole gives
meaning to parts, there is an emphasis upon inductive inference from description. This is
like Max Weber's notion of "ideal types" that are general to many cases.

Theories of Comparative Criminology

Comparative criminology theories with empirical support are the following (Scheider,
2001):

1. Alertness to Crime Theory-The people's alertness to crime is heightened as the

society develops or progresses as result, more crimes are reported which increases the
and demand for the police to become more effective at solving crime problems.
It relates to "proactive policing which refers to all policing strategies with the goal of
crime prevention or reduction that are not reactive primarily on uncovering ongoing
crime or on investigating or responding to crimes once they have occurred.

2. Economic or Migration Theory-This theory supposes that labor markets and

economies are driven by trade and migration. Migrants move from societies where labor
is abundant and wages are low, to societies where labor is scarce, and wages are high. As
a result, crime is everywhere, most especially in over-populated urban areas.

The economic theory of criminal behavior is an application of the neoclassical theory of

demand. Formalized by Nobel Laureate Gary Becker in 1968, it states that potential
criminals are economically rational and respond significantly to the deterring incentives
by the criminal justice system. They compare the gain from committing a crime with the
expected cost, including the risk of punishment.

3. Opportunity Theory - It seeks to explain the occurrence of crime rather than simply
the existence of criminal dispositions. Crime opportunity theory espouses that offenders
make rational choices, thus choose targets that offer high reward with little effort and
risk. Along with higher standards of living. victims become more careless of their
belongings, hence opportunities for committing crime multiply.

4. Demographic Theory-Is based on the belief that with the increase in the childbirth
rate, so does the emergence of delinquent subcultures as a result of adolescent identity
crisis.

Demographics, which are characteristics about a set of individuals, reveal patterns in

society concerning income, gender, education, or family status. However, demographics
can also provide data on crime. Criminologists use demographics to help understand why
crime occurs in certain locations. In addition, demographics help explain who commits
crime and the reasons why. The demographics of social class, age, gender, and race can
all be studied to understand crime.

5. Deprivation Theory- Espouses that along with progress. comes rising expectations.
Individuals at the bottom of the social class or hierarchy develop unrealistic expectations.
while those at the top do not see themselves rising fast enough.
In the Deprivation Theory, Individuals who are deprived money, justice, status, or
privilege, join social movements to express their grievances.
However, it is also important to look at relative deprivation theory where an individual
feels deprived by comparing what they have with what others have However, improved
conditions fuel human desires to aim for even better conditions.
On the other hand, absolute deprivation refers to the inability to access the basic
necessities in life such as food, shelter and clothing People below the poverty line mat
experience this.

6. Modernization Theory-Sees the problem as caused by the complexities of the

society.
This theory concludes that crime patterns are predictable and why criminal behavior in
developed countries is characterized by an increase in property crime and a relative
decrease in violent crime not associated with property crime.

The general rise in the crime rate and its concentration in the urban areas are due to the
greater availability of goods, the increased feasibility of crime commission, and the
increased feeling of relative deprivation because of a greater gap between the rich and
the poor. It may also be a result of deprivation awareness because of the various media
advertisements.

7. Theory of Anomie and Synnomie- Anomie suggests that progressive lifestyle and
norms result in the disintegration of older norms that once held people together. The
latter, synnomie, refers to social cohesion on values.
The idea of anomie means the lack of normal ethical or social standards. This concept
first emerged in 1893, with French sociologist Emile Durkheim. Durkheim's theory was
based upon the idea that the lack of rules and clarity resulted in psychological status of
worthlessness, frustration, lack of purpose, and despair.

Four (4) Types of Societies

There are four types of societies in the world that comparativists study

1. Folk-communal societies are also called primitive societies. Folk society is a society
of primary communal relationships with little complexity and largely insulated from
contact with other societies. It is morally, politically, and socially cohesive, because of the
isolated state of the people In this type of society, there is relatively unmediated personal
quality of social interaction, and the world experience is permeated with the
understanding and expression shared by all members. The folk society is generally
assumed to be the model of preliterate or so-called primitive societies

A folk-communal society has little codification law, no specification among police, and a
system of punishment However, when needed, they result to barbaric punishment
Classic examples of this form of society include the early Roman gentles, African and
Middle Eastern tribes, and Puritan settlements in North America (with the Salem).

2. Urban-commercial societies which rely on trade as the essence of their market

system.

An urban-commercial society has civil law where standards and customs are written.
Specialized police forces are intended for religious offenses, while others for enforcing
the King's Law In these societies, punishment is inconsistent, sometimes harsh,
sometimes lenient. Most of Continental Europe developed along this path.

3. Urban-industrial societies is a type of society where most of the goods and services
are produced without government interference.

An urban-industrial society not only has codified laws and statutes that prohibit, it also
has laws that prescribes good behavior. In this society, the police become specialized in
handling property crimes. The system of punishment is run on market principles of
creating incentives and disincentives. England and the U.S. followed this positive legal
path.

4. Bureaucratic societies are modern post-industrial societies where the emphasis is

upon technique or the "technologizing" of everything, with the government.

A bureaucratic society has a system of laws police who handle political crime and
terrorism, and a system of punishment characterized by over criminalization and
overcrowding. The U.S. and perhaps only eight other nations fit the bureaucratic pattern.
Juvenile delinquency is a phenomenon that only occurs in a bureaucratic society.

Model Country for Comparative Policing

Where are the best police forces in the world?

The duty of every police official is to uphold the security of the nation by combating
crime and to ensure that others are complying with the rules, regulations and
governmental laws. Below is a ranking of the top 10 countries with best police forces,
in relation is their performance and efforts as well as security measures and systems
in place to effectively enforce the low Each Police force are ranked according to their
training and performance.

1. England (Metropolitan/ Scotland Yard Police)

Metropolitan/ Scotland Yard Police is hailed as one of the best police forces. Their
notable project is launching a campaign to raise awareness of the police emergency
number This number awareness campaign enables people to be more knowledgeable
of the emergency services built to protect the nation as well as how to get in contact
with those who need assistance.
The Scotland Yard Police of the UK is spread out in all of the main cities and parts of
the outskirts. This way, police protection is everywhere.

2. Canada (Royal Canadian Mounted Police)

Even though Canada did not experience war driven situations like other countries.,
their police training is still above general standards. The police are prepared for
unpredictable situations similar to what Paris has experienced a few years back.
The government developed training colleges which enables officers to undergo
advanced and specialized development programs that prepares them for the reality in
the field. Having laid out to the trainee officers the expectations in the field, it creates
a realistic approach which they can adapt and implement when doing their duties
when the need arises.

3. Netherlands (Royal Mare Chaussee, The Gendarmerie)

The Dutch Police is extremely well-trained and disciplined. They are the nicest police
ever and work incredibly together. The Dutch Police has strategically placed and
positioned units. These units consist primarily of The Central Regional Police Services
which are under the command of the Dutch Commissioner.
Proper functioning and maintained order of the troops are taken by the responsible
duty of The Netherlands Minister of Justice ensures the proper function and maintains
order of the troops. Officers in these units are deployed and expected to be on standby
to conduct normal day-to-day duties and tasks that most of world's best police forces
undertake.

4. France (National Police of France)

The Gendarmerie Nationale is France's ace card or cannonball force when faced with
matters of destruction. They are the dedicated army force of France which is under
the Ministry of Defense. They are called upon handle extreme cases, such as terrorist
attacks and other major situations that France may face at any given time.
They are responsible in providing air support, ground support with tactical trained
teams' setup, put in position to move in on command, and conduct land operations to
smoother down the resistance.
They are always on stand-by ready to counter strike armed with a wealth of defense
mechanisms, skills, and training. They are under the command of by the French
Ministry of Defense.

5. Japan (National Police Agency)

The Japan police force is trained similar to the United States Military, Japan has the
highest training institute for leaders which trace back to the 60s'.
The structure of Japan's police training is regarded as one of the most intense,
versatile, and flexible. It covers almost every known aspect to crime prevention or law
enforcement.

6. USA (NYPD, LAPD, CHP)

Besides being known for their brutality, police forces are among the best polired with
a they are one of the highly trained forces in world, with a countless of backup and
rescue mediums as well as airssionary systems based across the country which makes
them unbeatable in terms of policing style. advanced American.
The US has several police departments. The NYPD (New York Police Department)
LAPD (Los Angeles NYPD Department), CHP (California Highway Patrol), are the
localized and standard force They are in-charged of everyday crimes that American
citizens are committing of victims to.

7. Australia (AFP)
The AFP is responsible for the seizure of one of the biggest drugs bust in the nation's
history, if not the only incident of this kind in Australia. An estimated amount of more
than a Billion Australian Dollars of Crystal Meth has been seized by this police force.
In addition, the AFP is one of the first police forces to effectively enforce and practice
gender equality. They plan to have more women in their police force where i more
than half of the force will be composed of women. This is considered as highly
effective in combating crime, since women are more prone to being mugged,
molested, and victimized in various heinous crimes. Having women in the police force
helps tremendously in the implementation of the law and the protection of the
citizenry, most especially the women.
8. Germany (Federal Police Bundespolizei or BPOL)
Germany has established 'Deutsche Hochschule der Polizei (German Police
University) which is the official and designated university where police newbies
undergo intensive study and training before deployed in physical on- the-field training
which is quite intense as every other force.

In Germany, each newbie is educated of the justice system. The university serves as a
regulatory education provider which ensures that all newbie have the same
knowledge of the justice system and is trained in the government prescribed
standards

9. China (The People's Armed Police Force)

"All Chinese are Kung-Fu masters" is most common impression of this police force.
This impression is formed due to the ability of the members of this police force to
master the art of body sequence moves in disabling an opponent or in manipulating an
opponent to completely paralyze them. This ancient method is being incorporated in
the Police Training in China.
The tactical operations of the Chinese Police force are among the world's best police
forces. It is perceived to be unique and effective compared to other police forces due
to the use of creativity and brashness of the police officers in this country. Having a
great amount of discipline instilled among the Chinese Police Officers, this ensures
accuracy in their shooting, hand to hand combats stance, and stature. Stealth is also
developed which is an advantage in advanced cases where silence is the key to end
violence. It gives officers the fortitude of maintaining discretion to handle situations
according to the extent of its magnitude.

10. Italy (Italian National Police)

The Italian National Police is regarded as one of the best trained law enforcements
because of their exclusive establishment and effective implementation of the "Italian
Anti- Mafia" division which is responsible for the arrests of the 2 o most dangerous
and violent mafia bosses who were hidden in the depths of barren mountains. This
achievement is considered a feat because the mafia is one of the most powerful and
influential group which conducts ruthless and inhumane acts to advance their
intentions or plans.