France was a keen supporter of an international approach towards drug prohibition.
Expansive or restrictive attitude on the prohibition of narcotic substances: +
Expansive or restrictive attitude on the prohibition of psychotropic substances: +
International agreement on demand-side measures: –
Counterfoil forms for the medical prescription of drugs: +
France had a favourable attitude on the prohibition of both narcotic drugs and psychotropic substances.
Preferred geographical framework: universal UN regime
France wanted a universal drug prohibition regime at the UN level. Before the Single Convention or 1961, the regime had not been entirely universal.
UN Fund for Drug Abuse Control (UNFDAC): –
For a strong institutional mechanism (CND, INCB): +
Appeals committee vs. arbitration committee: +
Embargo against states contravening the regime: –
France supported a significant institutional strengthening of the drug prohibition regime, although Paris did also have some reservations (especially on the UNFDAC and on embargos against states contravening the regime).
Germany was generally in favour of an international approach towards drug prohibition, although Bonn tended to be rather hesitant on substantive issues.
Expansive or restrictive attitude on the prohibition of narcotic substances: –
Expansive or restrictive attitude on the prohibition psychotropic substances: –
International agreement on demand-side measures: +
Counterfoil forms for the medical prescription of drugs: –
Germany had a favourable attitude on the prohibition of narcotic drugs, and a negative attitude on the prohibition of psychotropic substances.
Preferred geographical framework: universal UN regime
Germany wanted a universal drug prohibition regime at the UN level. Before the Single Convention of 1961, the regime had not been entirely universal.
UN Fund for Drug Abuse Control (UNFDAC): +
For a strong institutional mechanism (CND, INCB): +
Appeals committee vs. arbitration committee: ±
Embargo against states contravening the regime: –
Short of an embargo against states contravening the regime, Germany did support the institutional strengthening of the drug prohibition regime.
From 1972, Italy was in favour of an international approach towards drug prohibition (in 1961 Italy had not been accredited to the UN conference for the Single Convention on Narcotic Drugs, and in 1971 the country had kept a relatively low profile at the UN conference on psychotropic substances).
Expansive or restrictive attitude on the prohibition of narcotic substances: ±
Expansive or restrictive attitude on the prohibition of psychotropic substances: –
International agreement on demand-side measures: ±
Counterfoil forms for the medical prescription of drugs: ±
Italy had a favourable attitude on the prohibition of narcotic drugs, and a relatively sceptical (although not entirely negative) attitude on the prohibition of psychotropic substances.
Italy did not insist on a global drug prohibition regime, although it wanted to see enlisted as many countries as possible.
Italy did not aim at any recognizable change in comparison to the situation before 1961 (the drug prohibition regime had been near-universal already before the 1961 Single Convention on Narcotic Drugs).
UN Fund for Drug Abuse Control (UNFDAC): +
For a strong institutional mechanism (CND, INCB): +
Appeals committee vs. arbitration committee: ±
Embargo against states contravening the regime: ±
During the 1970s, Italy increasingly supported the institutional strengthening of the drug prohibition regime.
The British Government never challenged the idea of international drug prohibition (nevertheless it is fair to say that, in the 1960s and 1970s, London took a rather minimalist stance).
Expansive or restrictive attitude on the prohibition of narcotic substances: –
Expansive or restrictive attitude on the prohibition of psychotropic substances: –
International agreement on demand-side measures: –
Counterfoil forms for the medical prescription of drugs: –
Britain had a favourable attitude on the prohibition of narcotic drugs, and a negative attitude on the prohibition of psychotropic substances.
Preferred geographical framework: universal UN regime (Britain even declared that it preferred a thin but universal drug prohibition regime to a more demanding regime without universal membership.)
Britain wanted a universal drug prohibition regime at the UN level. Before the Single Convention or 1961, the regime had not been entirely universal.
UN Fund for Drug Abuse Control (UNFDAC): –
For a strong institutional mechanism (CND, INCB): –
Appeals committee vs. arbitration committee: +
Embargo against states contravening the regime: –
During the 1970s, Britain stuck to its preference that international drug prohibition should be limited to a small number of general principles, and that as much discretion as possible should be left to national legislation.
France is very fond of drug prohibition, both at the UN level and in the EU.
a) Supply side:
Criminalization of precursor substances: +
Crop eradication in Afghanistan and elsewhere: +
b) Demand side:
Tough line on controlled consumption, methadone, etc.: +
Tough line on “soft drugs” such as cannabis: +
There is no significant change in comparison to the situation in the early 1990s (France has a long standing as a hardliner in international drug prohibition).
a) Supply side: Preference for the universal UN drug regime (4)
b) Demand side: Preference for a regional EU drug regime (2)
a) Supply side: 0
The preferred geographical framework on the supply side continues to be the UN drug prohibition regime.
b) Demand side: +2
Shift from no international framework (0) to a the EU as the preferred geographical framework (2) for the demand side
Tangible commitment to international drug prohibition efforts: +
Budget share at UNDCP compared to budget share at UN: –
Minimum standards for penalties for drug dealers: +
Obligation to act against drug tourism (Netherlands): +
France would welcome a further institutional development of the drug prohibition regime, both at the UN level and in the EU.
Germany supports international drug prohibition, despite one or two de-facto opt-outs from the UN regime.
a) Supply side:
Criminalization of precursor substances: +
Crop eradication in Afghanistan and elsewhere: –
b) Demand side:
Tough line on controlled consumption, methadone, etc.: –
Tough line on “soft drugs” such as cannabis: ±
Apparently, Germany would like to reduce the scope of the UN regime both on the supply side and on the demand side. With its harm reduction policy (notably drug injection rooms), Germany has touched the limits of what is acceptable under the UN regime. Moreover, Germany would like to see an end to some repressive practices on the supply side such as crop eradication in the producing countries.
a) Supply side: Preference for bilateral development cooperation with the drug producing countries (1)
b) Demand side: Preference for a regional EU drug regime (2)
a) Supply side: -3
Shift from the UN (4) to bilateral cooperation as the preferred geographical framework (1) for the supply side
b) Demand side: +2
Shift from no international framework (0) to a the EU as the preferred geographical framework (2) for the demand side [ but open breach of the three UN conventions avoided ]
Tangible commitment to international drug prohibition efforts: +
Budget share at UNDCP compared to budget share at UN: –
Minimum standards for penalties for drug dealers: +
Obligation to act against drug tourism (Netherlands): +
Germany does not support a tougher drug prohibition regime. Berlin is rather critical about the principles underlying global drug prohibition, although it does not openly challenge the UN regime; at the same time, Germany it is committed towards the construction of an alternative (and relatively soft) demand side regime based on harm reduction.
The hard line of the second Berlusconi government is fully in line with the philosophy of the UN drug prohibition regime.
a) Supply side:
Criminalization of precursor substances: +
Crop eradication in Afghanistan and elsewhere: ±
b) Demand side:
Tough line on controlled consumption, methadone, etc.: +
Tough line on “soft drugs” such as cannabis: +
While Italy had become rather lenient in the 1990s, under the second Berlusconi government the country has become a hardliner.
a) Supply side: Preference for the universal UN drug regime (4)
b) Demand side: Preference for a universal UN drug regime (4)
a) Supply side: 0
The preferred framework on the supply side continues to be the UN drug prohibition regime.
b) Demand side: +4
Shift from no international framework (0) to a the UN as the preferred geographical framework (2) on the demand side
Tangible commitment to international drug prohibition efforts: +
Budget share at UNDCP compared to budget share at UN: +
Minimum standards for penalties for drug dealers: +
Obligation to act against drug tourism (Netherlands): –
Italy has always been active in support of the UN drug prohibition regime (especially in the UNFDAC), but with the second Berlusconi government the Italian policy on international drug prohibition has turned even more determined.
Despite some problems with compliance, Britain is mostly loyal towards the UN regime.
a) Supply side:
Criminalization of precursor substances: +
Crop eradication in Afghanistan and elsewhere: +
b) Demand side:
Tough line on controlled consumption, methadone, etc.: –
Tough line on “soft drugs” such as cannabis: –
Britain has become somewhat subversive on the demand side of the drug prohibition regime, but seems to be harder than ever before on the supply side.
a) Supply side: Preference for the universal UN drug regime (4)
b) Demand side: De facto preference for a national approach (0)
a) Supply side: 0
The preferred framework on the supply side continues to be the UN drug prohibition regime.
b) Demand side: 0
Britain continues to prefer no international regime on demand reduction.
Tangible commitment to international drug prohibition efforts: +
Budget share at UNDCP compared to budget share at UN: ±
Minimum standards for penalties: +
Obligation to act against drug tourism (Netherlands): ±
Britain's preferences concerning the institutional strength of the drug prohibition regime have not significantly changed over the last ten or fifteen years.
After the French Connection case, France was in favour of a coordinated approach to the development of drug enforcement methods.
a) Americanization:
Infiltration as an investigation technique: ±
Going for “Mr. Big” as an investigation technique: +
Other American-style investigation techniques: +
b) Europeanization:
Multidisciplinary approach towards the drugs problem: +
France was in favour of a coordinated approach towards drug enforcement techniques.
Preferred geographical framework: transatlantic level and Pompidou group.
Shift from no international cooperation to cooperation at the transatlantic level and in the Pompidou group.
a) Americanization:
“Soft” learning from the US (visits etc.): +
“Intense” learning from the US II (courses, internships, etc.): +
b) Europeanization:
Approximating/harmonizing legislation in Europe: +
Systematic information exchange beyond Interpol: +
Since the French Connection case, France had a strong preference for the institutional development of international cooperation on drug investigation techniques. The American BNDD was welcomed in Paris; there were meetings with the BNDD every 3 months; France did even start “teaching” investigation techniques, and recommended the US-French memorandum of understanding as a blueprint for other European states
Germany was in favour of a coordinated approach to the development of drug enforcement methods.
a) Americanization:
Infiltration as an investigation technique: +
Going for “Mr. Big” as an investigation technique: +
Other American-style investigation techniques: +
b) Europeanization:
Multidisciplinary approach towards the drugs problem: +
Germany was in favour of a coordinated approach towards drug enforcement techniques.
Preferred geographical framework: transatlantic level and Pompidou group.
Before the 1970s, cooperation had been limited to coordination with the American CIDs to fight drugs in US military bases; thereafter, Germany had a preference for cooperation at the transatlantic level and in the Pompidou group.
a) Americanization:
“Soft” learning from the US (visits etc.): +
“Intense” learning from the US II (courses, internships, etc.): +
b) Europeanization:
Approximating/harmonizing legislation in Europe: +
Systematic information exchange beyond Interpol: +
Germany was in favour of the institutional development of international cooperation on drug investigation techniques.
Italy was in favour of a coordinated approach to the development of drug enforcement methods.
a) Americanization:
Infiltration as an investigation technique: +
Going for “Mr. Big” as an investigation technique: +
Other American-style investigation techniques: ±
b) Europeanization:
Multidisciplinary approach towards the drugs problem: +
Italy was in favour of a coordinated approach towards drug enforcement techniques.
Preferred geographical framework: transatlantic level and Pompidou group.
Shift from no international cooperation to cooperation at the transatlantic level and in the Pompidou group.
a) Americanization:
“Soft” learning from the US (visits etc.): +
“Intense” learning from the US II (courses, internships, etc.): +
b) Europeanization:
Approximating/harmonizing legislation in Europe: +
Systematic information exchange beyond Interpol: ±
Italy was in favour of the institutional development of international cooperation on drug investigation techniques.
In the 1970s, British decision makers almost completely abstained from formulating official “national” preferences with regard to the investigation techniques that should (or should not) be adopted by the police in the prosecution of drug-related crime.
Not addressed
Not verifiable
Not addressed
Not verifiable
Not addressed
Not verifiable
France is in favour of international cooperation against money laundering.
Lifting the banking secrecy: +
Lifting the professional secrecy for lawyers: +
Fusion of the money laundering regime with tax evasion: +
Control of large cash transactions: +
France did fully support the shift from no anti-money laundering regime (in the 1980s) towards a strong regime.
Preferred geographical framework: FATF
Shift from no international anti-money laundering regime in the early 1980s to the FATF as the preferred geographical framework.
Shifting the burden of proof: ±
Tighter control of offshore activities: +
Tangible support to vulnerable countries: +
Readiness for international asset sharing: ±
France has supported a shift from no international anti-money laundering regime in the early 1980s towards a strong regime.
At least since 1998, Berlin is in favour of international cooperation against money laundering (although it is fair to say that Germany never was a particularly active supporter).
Lifting the banking secrecy: –
Lifting the professional secrecy for lawyers: –
Fusion of the money laundering regime with tax evasion: +
Control of large cash transactions: ±
Germany has been, and partially still is, a relatively lukewarm supporter of the anti-money laundering regime.
Preferred geographical framework: FATF
Shift from no international anti-money laundering regime in the early 1980s to the FATF as the preferred geographical framework.
Shifting the burden of proof: ±
Tighter control of offshore activities: ±
Tangible support to vulnerable countries: ±
Readiness for international asset sharing: –
Germany has supported a shift from no international anti-money laundering regime in the early 1980s towards a relatively strong regime, given domestic constraints.
Italy is in favour of international cooperation against money laundering.
Lifting the banking secrecy: +
Lifting the professional secrecy for lawyers: ±
Fusion of the money laundering regime with tax evasion: +
Control of large cash transactions: +
Italy did fully support the shift from no anti-money laundering regime (in the 1980s) towards a strong regime.
Preferred geographical framework: EU
Shift from no international anti-money laundering regime in the early 1980s to the EU as the preferred geographical framework.
Shifting the burden of proof: ±
Tighter control of offshore activities: +
Tangible support to vulnerable countries: –
Readiness for international asset sharing: –
Despite domestic constraints, Italy has supported a shift from no international anti-money laundering regime in the early 1980s towards a strong regime.
Britain is in favour of international cooperation against money laundering.
Lifting the banking secrecy: +
Lifting the professional secrecy for lawyers: ±
Fusion of the money laundering regime with tax evasion: ±
Control of large cash transactions: –
Britain did fully support the shift from no anti-money laundering regime (in the 1980s) towards a strong regime.
Preferred geographical framework: universal
Shift from no international anti-money laundering regime in the early 1980s to the whole world as the preferred geographical framework.
Shifting the burden of proof: +
Tighter control of offshore activities: ±
Tangible support to vulnerable countries: +
Readiness for international asset sharing: +
Britain has supported a shift from no international anti-money laundering regime in the early 1980s towards a strong regime.
After the French Connection case, France was genuinely committed towards international police cooperation to suppress drug trafficking.
Exchange of information and personnel in joint investigations: +
Operating on drug producing and transit countries: +
Migration control (including expulsion and preventive measures): +
Customs and police cooperation: +
Shift from no agreement to a detailed protocol with the US and own initiatives at the European level
Preferred geographical framework: collaboration beyond Europe (most prominently with the US, but also with Spain, West-Germany, and Turkey)
During the 1960s, France had not yet been willing to cooperate with the US on the fight against drug trafficking. By the early 1970s, France had a preference for a variety of agreements and activities with a broad geographical range.
Bilateral agreements on operational police cooperation: +
Executive power for foreign agents on national territory: –
Exchange of liaison officers and/or special envoys: +
Technical aid for producing countries: +
On occasion of the French Connection case, Paris took a very strong commitment for formal institutional coordination with the US agencies, including the carrying out of joint investigations.
At the beginning, Germany was active mostly due to US pressure. Over the 1970s, however, Germany became genuinely committed towards international police cooperation to suppress drug trafficking.
Exchange of information and personnel in joint investigations: +
Operating on drug producing and transit countries: +
Migration control (including expulsion and preventive measures): +
Customs and police cooperation: +
Shift from no action (except for US military bases in the late 1960s) towards a web of intense cooperation around 1980, including a protocol with the US (1978) and with Turkey (1981), plus customs cooperation agreements with a variety of states.
Preferred geographical framework: collaboration beyond Europe (Germany desired bilateral and multilateral cooperation in Europe and beyond, involving especially the transit and consumer countries and, as far as possible, also some source countries such as Turkey).
Already in the 1960s, Germany had cooperated on a bilateral basis with the US concerning drugs in the American military bases. By the late 1970s, Germany had a preference for a variety of agreements and activities with a broad geographical range.
Bilateral agreements on operational police cooperation: +
Executive power for foreign agents on national territory: –
Exchange of liaison officers and/or special envoys: +
Technical aid for producing countries: +
Although not as much as Paris on occasion of the French Connection case, Germany took a strong commitment for formal institutional coordination.
By the early 1970s, Italy did not yet have a coherent set of preferences on international police cooperation to suppress drug trafficking.
Not addressed.
Not verifiable
Preferred geographical framework: only ad hoc cooperation (no bilateral agreements before the second half of the 1970s)
No takeoff in the first half of the 1970s.
Not addressed
(Italy had strong reservations against shortcutting Interpol)
Not verifiable
In the early 1970s, the political establishment in the UK was not yet sufficiently motivated to formulate a coherent set of national preferences on international police cooperation to suppress drug trafficking.
Not addressed
Not verifiable
Preferred geographical framework: only ad hoc cooperation (no bilateral agreements in the 1970s; the “Draft for a Home Office circular for urgent drug cases involving France” does not count as such an agreement)
No takeoff in the first half of the 1970s.
Not addressed
Not verifiable
France was among the initiators of the framework decision on joint investigation teams and supported the participation of Europol. Accordingly, one can safely assume that the country did want a multilateral umbrella for joint investigation teams in Europe.
Joint investigation teams shall be applied to all sorts of crime: +++
Multinational ad hoc teams for exchanging information on terrorists: +
The EU regime is set to complement (not supersede) an already existing network of bilateral agreements. Despite the institutional innovation, the substantive scope of international cooperation is unlikely to increase significantly. The regime has the same scope as before with the additional possibility of using the EU umbrella.
Preferred geographical framework: EU
Shift from bilateral cooperation towards a regional framework in the EU
Right of participation for Europol: +
Right of initiative for Europol: +
Delegation of executive competences to foreign police officers: –
Commitment towards implementation: +
France wants that Europol shall be allowed to initiate investigations and shall be deeply involved in joint investigation teams. French representatives are strongly promoting the quick establishment of joint investigation teams with a variety of countries. All this would amount to a clear progress in comparison with the situation before 2000.
Being in favour of a “European FBI”, Germany was perforce in favour of joint investigation teams (although joint investigation teams can also be seen as a surrogate to real investigative and coercive powers for Europol).
Joint investigation teams shall be applied to all sorts of crime: +++
Multinational ad hoc teams for exchanging information on terrorists: +
The EU regime is set to complement (not supersede) an already existing network of bilateral agreements. Despite the institutional innovation, the substantive scope of international cooperation is unlikely to increase significantly. The regime has the same scope as before with the additional possibility of using the EU umbrella.
Preferred geographical framework: EU
Shift from bilateral cooperation towards a regional framework in the EU
Right of participation for Europol: +
Right of initiative for Europol: +
Delegation of executive competences to foreign police officers: +
Commitment towards implementation: ±
In principle, the German preferences would go far beyond joint investigation teams: true investigative and coercive powers to Europol.
Despite problems with ratification, Italy did want a multilateral umbrella for joint investigation teams in Europe and supported Europol participation.
Preferred focus on terrorism, drugs, and trafficking in human beings: ±
Multinational ad hoc teams for exchanging information on terrorists: +
The EU regime is set to complement (not supersede) an already existing network of bilateral agreements. Despite the institutional innovation, the substantive scope of international cooperation is unlikely to increase significantly. The regime has the same scope as before with the additional possibility of using the EU umbrella.
Preferred geographical framework: EU
Shift from bilateral cooperation towards a regional framework in the EU
Right of participation for Europol: +1
Right of initiative for Europol: +1
Delegation of executive competencies to foreign police officers: ±
Commitment towards implementation: -1
According to the Italian Minister of Interior the final objective is to entrust Europol with the coordination of European investigations on terrorism. But if one looks beyond rhetoric, it is telling that almost two years after the deadline, the framework decision on joint investigation teams has still not been ratified by the Italian parliament. In particular, the Italian judiciary seems to have problems with the usage of evidence that has not been gained according to Italian standards.
Britain was among the initiators of joint investigation teams and supported the participation of Europol. Accordingly, one can safely assume that the country did want a multilateral umbrella for joint investigation teams in Europe.
Joint investigation teams shall be applied to “organized crime groups across the full range of their activities”: +++
Multinational ad hoc teams for exchanging information on terrorists: ±
The EU regime is set to complement (not supersede) an already existing network of bilateral agreements. Despite the institutional innovation, the substantive scope of international cooperation is unlikely to increase significantly. The regime has the same scope as before with the additional possibility of using the EU umbrella.
Preferred geographical framework: EU
Shift from bilateral cooperation towards a regional framework in the EU
Right of participation for Europol: +
Right of initiative for Europol: ±
Delegation of executive competences to foreign police officers: –
Commitment towards implementation: ±
The EU regime will complement (not supersede) an already existing network of bilateral agreements. In the British case the usage of the new instrument is completely optional, and therefore there doesn’t seem to be any strong institutional commitment from the British side.