Comparative Analysis of Criminal Policies to Combat Economic Corruption in Iran and Selected Legal Systems (with Emphasis on French and German Experiences)

Economic corruption remains a profound and multifaceted challenge for both developed and developing nations, undermining the rule of law, eroding institutional legitimacy, and distorting economic development. This article critically examines and compares the evolution, design, and effectiveness of criminal policies formulated to combat economic corruption in Iran, drawing analytically on the comparative experiences of France and Germany as two advanced legal systems within the civil law tradition. The primary objective of the article is to identify the strengths and weaknesses of Iran’s current anti-corruption strategy and to distill practicable reform pathways by leveraging comparative insights from the French and German models. The study adopts a review-based, doctrinal approach, encompassing a detailed exploration of statutory frameworks, enforcement practices, institutional architectures, and international obligations as they relate to economic corruption. The research begins by outlining the theoretical foundations and legal definitions of economic corruption within the context of criminal law, emphasizing how local legal cultures, historical legacies, and socio-economic dynamics shape both policy formation and enforcement contexts. The Iranian experience, characterized by the integration of Islamic jurisprudence with civil and criminal codes, is critically analyzed with special attention given to recent legislative actions, the establishment of specialized anti-corruption courts, and ongoing institutional challenges—such as political interference, lack of transparency, and insufficient coordination among oversight bodies—that hinder effective implementation. In comparative perspective, the article elucidates how France’s multi-layered strategy—anchored in recent legislative reforms like the Sapin II Law, robust compliance requirements, and the creation of the French Anti-Corruption Agency—has enabled the country to evolve toward a preventative, institutionally coordinated, and internationally harmonized approach. Similarly, the German model is highlighted for its legal clarity, procedural safeguards, decentralized investigative structure, and adherence to international anti-corruption conventions. Both countries’ successes and remaining obstacles serve as benchmarks to critically assess Iran’s anti-corruption efforts. Ultimately, the article demonstrates that the effectiveness of anti-corruption criminal policies is contingent upon a combination of legislative coherence, institutional independence, preventive measures, and active civic engagement.

کلیدواژه ها:

Economic corruption ، criminal policy ، Iran ، France ، Germany