عنوان مقاله [English]
Request for criminal or criminal prosecution of cross-border offenses in the territory of the European Union has a pattern of mutual cooperation, the principle of mutual recognition and the provision of criminal investigations. This is an alternative approach to the Transnational Criminal Procedure Code and to the harmonization of the internal rules of the member states of the European Union, which now does not provide for the conditions for its implementation in the European Union. It is believed that the field of harmonization of the domestic laws of member states is consistent with the principles of the criminal procedure with the experience of mutual cooperation, mutual identification and criminal investigation. However, the principle of mutual recognition and criminal investigations has serious gaps that, until these problems are resolved, there is no prospect of harmonizing the internal laws of the member states. Mutual identification or criminal investigation of non-criminal acts that are subject to the termination of the law, differences in the standards of criminal law, or in conflict with national sovereignty and red lines have failed. Same is true of the adoption of the Transnational Criminal Procedure Act and the harmonization of the laws of member states in the future.