CHAPTER

ONE

Introduction to the Comparative Perspective in Criminology

Criminology has existed as a discipline examining crime and law for over 250 years. As a field of study, it is relatively new, however its focus on behavior that violates the legal code of a society examines actions committed by humans that have existed for many centuries prior. Piracy for example, illustrates how long criminal acts have existed that required a response from the state, as was faced by the Romans (). What is unique  in the case of the piracy that threatened Roman commerce is that the pirates were from other nations. The issue then has been that crime has long had an international component. While some may not think of ancient pirates as being transnational criminals, their activities and methods have striking similarities to transnational crime in the present whether it is in the form of drug, human, or arms trafficking. Transnational crime involves criminal offences whose origin, number and/or express or indirect effects entail two or more countries. The effect of transnational criminal activities on both United States and the world stage is one of the many reasons that comparative criminology is of growing importance to our understanding of crime. Comparative criminology as an area of study focuses on empirical and theoretically based examinations of crime in two or more societies (Beirne and Nelken, 1996).

Figure 1.1: A Roman ship under attack by pirates

The sociological perspective influences comparative criminology and is therefore concerned with understanding why crime exists in a society in the forms and amounts it takes. Some of these crimes take the form of street crimes and others are larger in scope than those committed by individuals. Crimes committed by the state as well as national, ethnic, racial, and religious groups that result in violations of human rights are also of concern to comparative criminologists. Further, a growing concern with crimes of an environmental nature are also influencing comparative criminologists. As a result, the discipline of comparative criminology is often more critical of crime than typical arenas of study in the field of criminal justice.

Given that the majority of criminology and criminal justice has been generated by scholars in the United States the need to study crime in other societies stems from a number of issues relating to this body of knowledge. Scholars must acknowledge the influence that cultural context has on the development of a discipline and the limitations this places on the understanding specifically of crime in the field of criminology in the U.S. The sociology of knowledge approach illustrates that any discipline is grounded within the social ideas connected to both the geographic and temporal features of the culture(s) within which it develops (Smith, 1975; Glick, 1987; Goetzman, 1992). The assumption that Western models of crime control are the most advanced is especially limited and the resulting problems from this export of these ideas means that we must be prepared to consider alternative approaches developed in the unique cultural contexts of the societies Western criminal justice professionals and criminologists seek to assist (Cohen, 1997). The practice of restorative justice also demonstrates that concepts of justice and social control from developing societies have valuable lessons for Western nations criminal justice practices (Braithwaite, 1997).

The primary reason to study criminology from a comparative perspective is centered on the concern about crime in other countries. Beginning in the 1700s with scholars such as criminologist Cesare Beccaria, Jeremy Bentham, Alexis de Tocqueville and sociologist Emile Durkheim have all engaged in studies of that compared crime in various nations. Criminal justice professionals also have been concerned with collecting data and gathering information on transnational crime since the 1850s. The world wars of the early twentieth century overshadowed international crime until the 1960s that a serious focus returned to these issues. The comparative perspective contrasts the mundane and banal that we may take for granted within our society with examples of different possibilities from other cultures. This allows for a better understanding of our own system and the possibility of new insight which can be used to improve our system.

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Organized crime groups operating in the U.S. had global partners; this was evident to U.S. agencies with the connections between the Mafia in the U.S. and in Sicily during the 1940s and 1950s. These connections were of concern for many of the member nations of the United Nations. Through the U.N. Crime Prevention and Criminal Justice Branch, the systematic sharing of information began to combat both the lack of information about these international criminal connections. Combined with the poor quality of the information available prior to this period meant that many agencies were unsure of the nature and extent of the organizations they were investigating (Dammer and Fairchild 2006). This shift in focus contributed to several criminologists beginning the active study of crime problems through comparisons with nations facing similar crime problems. Since the 1990s criminologists in the U.S. have increasingly emphasized the importance of comparative criminology (e.g. Adler 1996).

Figure 1.2: Cesare Bonesana di Beccaria

A second reason to study crime in other countries was to benefit from the experience of these nations in dealing with crime. The different perspective of other cultural experiences with crime helped to expand the knowledge we had about how crime occurred beyond the perspectives  developed by criminologists in the U.S. and as a result this new information allowed for new approaches to dealing with crime problems (Burnham, 1998). By expanding our understanding of different cultures and approaches to crime, problems it allows criminologists in the U.S. to better comprehend the limits of their knowledge and examine why certain approaches to crime may have been unsuccessful. By examining other cultures, we broaden our understanding about the issue we wish to examine. This is important considering that often the same solutions to crime are offered and yet little changes seem to have been made in the crime problems we continue to face in the U.S. The Japanese focus on community policing initiatives contributed to many countries examining these practices to see how utilizing this approach could address crime. In the U.S. community policing initiatives have been adapted in various cities from these Japanese programs. Law enforcement agencies also travel the world to engage in training in other countries. Organizations such as the Law Enforcement Management Institute of Texas (LEMIT) routinely engages in training with police agencies from such nations as South Korea, Thai- land, and Poland. Through LEMIT’s International Police Program, law enforcement officials engage in professional exchange programs allowing officers to learn more about criminal justice around the world. The Federal Law Enforcement Training Center (FLETC), established in 1970, also engages in international training and has oversight and program management responsibilities for the International Law Enforcement Academies (ILEA) in Gaborone, Botswana, San Salvador, El Salvador, and Lima Peru. It also supports training at ILEAs in Budapest, Hungary and Bangkok, Thailand. The International Center for the Prevention of Crime as well as the International Corrections and Prison Association are both also engaged in the collection and dissemination of information about criminal justice with countries around the world. Crime prevention strategies are now shared from both the West and from developing nations to developed nations.

International cooperation between law enforcement agencies also provides an opportunity for practitioners to gain insight into new approaches to illegal behavior. Partnerships between nations exist for a variety of reasons. For example, the United States and Canada have several treaties relating to the cooperation of law enforcement and the larger criminal justice system in each country. Extradition of criminals is one such example of cooperation, criminals often seek to exploit international borders to escape justice, without such intergovernmental cooperation agreements, criminals would be almost impossible to catch when they flee across an international border. Project North Star is another initiative designed to increase information sharing and training opportunities for federal law enforcement officials between the two nations (U.S. Department of State, 2008). Cooperation also takes place in the area of criminal investigations through programs such as the Border Enforcement Security Task Force (BESTs) and the Integrated Border Enforcement Teams (IBETs). In the case of the cooperation between the U.S. and Canada it has been considered a successful enterprise.

Figure 1.3: A modern drug trafficking operation

Cooperation however, between the U.S. and Mexico has several issues and points to a place for comparative criminology to offer potential solutions. The nature of the criminal justice cooperation between these countries has largely focused on the issue of drug trafficking. While both governments recognize the problems associated with drug trafficking many critics have pointed out the dominant position the U.S. has taken in this partnership and the subsequent concerns about sovereignty raised by Mexican officials (Toro, 1999). U.S. federal agents have arrested foreign nationals in Mexico which critics claim amount to kidnappings  by the U.S. government, combined with searches of property by U.S. law enforcement agents, grand jury indictments and judicial processing in U.S. courts, the sovereignty of Mexico is seen to be in question under these international agreements. The U.S. counters that the expertise of U.S. personnel in addition to greater access to equipment and technology results in the U.S. taking the lead in U.S. – Mexico law enforcement operations (Deflem, 2002). Further, the issue of corruption in Mexico amongst government officials and law enforcement has meant the U.S. at times has operated within Mexico without authorization from the Mexican government (Bureau for International Narcotics and Law Enforcement Affairs, 2006). In a 1998 case of money laundering sting in Mexico City these issues became especially evident and illustrates the complexity of international cooperation. The U.S. cited corruption and the safety of U.S. personnel as the reason for not seeking the proper permission for the operation as well as capturing drug traffickers (Sheridan, 1998). These actions raise serious questions regarding how such operations should be conducted while balancing the logistical realities of cooperating with partners where corruption is a serious issue.

Figure 1.4: A human trafficking operation

Another example of international cooperation comes in the form of the European Commission, an institution within the European Union (EU); this organization is responsible for joint efforts among the 25 member states criminal justice agencies (European Communities, 2006). The EU has resulted in the greater movement of Europeans across the borders of the member nations. Again, this creates the problem of criminals using borders to escape justice. The structure of the European Commission is to provide a supranational form of justice to deal with criminals who travel across borders in Europe. Information sharing is a key component for member agencies as well as support for investigations and prosecution. Perhaps of special interest is the provision which allows law enforcement from one European nation to pursue criminals across borders into other EU nations as well as the use of European arrest warrants which allows for the easier return of offenders to the country where they were accused or sentenced of a crime. These realities mean for both practitioners and scholars of comparative criminology, the need to understand the global reality of crime is growing. The benefits of cooperation between nations in dealing with transnational crime problems mean that they will continue in spite of problems that arise.

Cooperation and sharing of information mean that new practices and initiatives can be observed by law enforcement and government officials with greater ease. Practitioners therefore must consider the differences and similarities in the cultural practices of criminal justice initiatives when considering them for integration. For example, how shame works in a society depending on the level of interdependence between individuals has important consequences for how restorative justice can be applied in the U.S. where independence is more greatly valued (Levi, 2000). Restorative justice also demonstrates that developed nations have important lessons to learn about crime and justice from nations at different levels of development that have been historically viewed as being less “advanced.”

Figure 1.5: An arms trafficking operation

A final reason to study crime in other countries is concerned with helping approach the many transnational crime problems that the nations of the world currently face. Illicit drugs, weapons trafficking, human trafficking, cybercrime, and terrorism are just some of the crime problems with transnational elements. These threats to both the citizens of the U.S. are also threats to the citizens of various other nations around the world. The responses to these crime problems require complex approaches beyond simply those that address these challenges in the U.S. Due to the transnational nature of these crimes, the U.S. is not alone in facing them and so it is important for us to look to other nations and the way they address these issues as we develop our own solutions. If we hope to address these problems with any degree of effectiveness, we cannot assume that our solutions are the only or best solutions to these problems.

Keeping these elements in mind as we examine comparative criminology allows us to approach such issues as the crime rate of a nation within a context that allows us to determine with greater accuracy why there is more or less crime in a given location compared to another. Further, it sets boundaries on our knowledge so that generalizations about the causes of crime can consider any unique features of a society that may account for differences. This is of great importance when we consider the application of criminological theory across cultural contexts beyond those in which the theory was developed. This allows for a three-step process of testing knowledge derived from the work of Clinard and Abbott (1973). First, the testing of concepts and theories of crime must occur in one culture at one point in time. Then testing can occur in two societies with similar characteristics and finally testing in societies with cultural differences. The challenges here should caution us against relying solely on quantitative data as testing concepts especially in societies with greater numbers of cultural differences will also require the comparative criminologist to be familiar with qualitative data that allows for greater comprehension of unique cultural features in the societies being compared.

The Extent of Transnational Crime

The global criminal economy will be examined in more detail in subsequent chapters but a brief introduction to this issue is warranted. Globalization is the interconnectedness of events and the behaviors of people and social structures around the globe. No nation is exempt from the cultural and economic effects of globalization. From political and economic actions taken by nations, the effects of these state actors no longer influence only their own citizens but also citizens in other nations as well. Non-state actors also possess global influence. The United Nations Office on Drugs and Crime in 2009 estimated the global criminal economy to have generated $870 billion (United Nations, 2010). Recent estimates have placed that figure in excess of one trillion U.S. dollars. Organized crime groups such as the Yakuza, Russian Mafia groups, MS-13, and drug cartels have criminal activities that cross borders to generate profit for the group. Mid and low-level organized crime players that deal in weapons, stolen cars, and human trafficking also benefit from transnational criminal activities. The result is money that crosses borders and influence of a political, economic, and social nature being available to these criminals. To trace the development of this  global criminal economy we must  look  to the growth of globalization following the end of World War II. The devastation across Europe and in other nations around the world meant that the U.S. had a unique position to aid in the reconstruction of industry on a global scale. With the U.S. remaining as the dominant economic and military power following the war, the business opportunities available in assisting the nations of the world rebuild resulted in many changes. One example is the export of the assembly line process of manufacturing to Japan. Sharing our talents meant developing and strengthening networks of communication and transportation for use by U.S. business. These phenomena increased even more drastically following the dissolution of the Soviet Union in the 1990s and the creation of free-trade blocks such as the North American Free Trade Agreement (NAFTA), the European Union (EU), as well as the Commonwealth of Independent States (CIS). The result as many scholars of globalization have noted was the “shrinking of the world” as people, money, and social influence moved with greater ease. The benefits to business allowed for the creation of multinational corporations and unprecedented world trade. These developments also opened new opportunities for criminal groups on the world stage. One of those consequences meant that organized crime groups could exploit these same tools used by international business used to ship drugs from the continents of Asia and South America across the world to the West. Air travel specifically has allowed individuals to escape criminal prosecution as well as allowing for human trafficking to take place on commercial flights. The development of telecommunication networks has played a vital role in the growth of cybercrime globally.

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Globalization has ushered in an age of international cooperation and networking. Boundaries that previously made these networks difficult to establish are vanishing allowing organizations access to global partners that geography and language previously prevented (Friedman, 2005). Crime on an international scale has now expanded the scope of victimization beyond the individual as a result, jeopardizing entire communities, government agencies and elected officials, and even the sovereignty of nations. Dealing with the expanded scope of criminality means that law enforcement agencies must adapt to the changing scale of crime in an increasingly global arena.

For the criminal justice professional as well as the criminologist, understanding the criminal justice system of other nations has become essential. Knowledge of the problems facing the law enforcement community in any given country can help with sensitive international investigations as cooperation between agencies in the U.S. and their foreign partners becomes increasingly essential. Drug traffickers and terrorist networks have required increasing cooperation to deal with the flow of black-market goods and money used to fund these organizations. Government corruption is just one barrier U.S. agencies must be aware of and overcome as international cooperation increases. These barriers to international law enforcement cooperation are being dealt with as agencies develop responses to the international crime problems that arise.

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Some scholars have argued (Hippchen 1977, 1987) that various issues of social disorder beyond crime need also to be considered. Environmental issues as well as social injustice in general should also be considered when examining comparative criminology. In part because the overlap between crime and social injustice as well as the growing field of environmental criminology mean these issues are interconnected. If government officials are to take any action, they should do so with a comprehensive understanding of the structural nature of crime on the global stage. This focus  on application should be essential in the study of comparative criminology while being balanced with the development of theory and empirical research. We must exercise caution that any application of material based in the research of comparative criminologists does not ignore unique cultural variations outside of the U.S. to avoid the supposed “expertise” of the criminology developed in the United States. Therefore, a critical perspective should also be an essential component of comparative criminology. Further, a broad definition of crime must also be adopted to account for power differentials especially when human rights violations are perpetrated by state actors. The result is a broad range of topics for comparative criminologists to examine.

However, the limits of our knowledge of the extent and nature of international crime by the complex nature of transnational crime and the involvement of actors in different countries means that accuracy will be a problem. Various studies have given us glimpses at the degree of international crime and we should be aware that any information we have be carefully considered for accuracy and efforts must continue to be made to improve our knowledge of the issues we will examine in the field.

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The Problem of Culture

Comparative criminologists quickly noted that there were vast differences in the way crime was socially constructed in the countries they examined. Contrary to the beliefs of many, crime is not a biological process caused by some faulty gene. Crime is a social construct, through social processes that create laws, formalizing the norms that guide our interactions into a legal code a society decides what actions are criminal and who is a criminal. These social processes reflect a complex web of political and governmental actions in developing policy, social and economic conditions and other unique historical effects that take place in a cultural environment at both the macro and micro level. The result includes differences in the rights of offenders in the criminal justice system as well as public response to offenses. Every aspect of the criminal justice system from the police to the courts, to correctional institutions bears the marks of these structural forces. In every society that criminologists have examined women, commit less crime than men do. One common explanation for this phenomenon involves the socialization of men to be risk takers in society, which may encourage their involvement in criminal acts. Some scholars point to the obvious differences of biology, citing the hormone testosterone and other androgens in contributing to differences in men’s behavior. While testosterone has been linked by some studies to elevated levels of aggression in men, the question why so many men do not commit crime remains. In addition, most crimes are not violent crimes, so how can testosterone be linked to the most common form of crime which involves property. These issues point to the important role of sociological and psychosocial processes in creating human behavior.

Another common finding among comparative criminology studies is the issue of how old criminals are (Braithwaite, 1989). In general, law violating behavior is most common between the ages of 14 and 24, with a sharp decline after the mid-20s. Not that people cannot commit crime into their 70s or beyond, but adolescents and young adults commit the majority of crime in a society. While neurological studies show some possible issues related to development of certain parts of the brain, again the question of why most people do not commit crime remains. A more commonly accepted explanation among criminologists is the issue of social bonds to society. Adolescents and young adults are engaged in a process of identity formation where peer influences become increasingly important. While bonds exist between youth and their families, these bonds are not as strong as they will be later in life. Given these weaker ties, there are fewer potential aspects of their life to restrict their behavior. Consider this example. An adult who is married with children, has a full-time job, a mortgage payment, a dog, and a loan for a minivan risks a great deal more when a crime is committed than the average teenager. While the types of bonds vary by society, youth in countries with more bonds at younger ages have been found to commit less crime than youth in the U.S. at similar ages. India, China, and Japan have historically had some of the lowest levels of youth crime in the world.

The last finding that comparative criminologists have found to be common to all societies where crime has been studied has been labeled by some scholars as the 5/95% phenomenon (Braithwaite, 1989). While the numbers are really nothing more than a rule of thumb, these studies show  us that in any society only a small percentage of the society is engaged in law violating behavior, roughly around 5% at any given time. Although in some countries, it would appear to be more or less, it is relatively a small group when the society as a whole is considered. This has then led to another discovery. Of that active “5%” of criminals in a society, about 80% give up their involvement in law violating behavior after a short period of time. Many criminologists conclude that the most severe offenders who commit many more times as much crime as the average criminal commit about 20% of the crime in a society. Yet despite these similarities, we still experience the problem of nations with lower crime rates. In these cases, such as Japan and Ireland, the placing of emphasis  on unique cultural features at the expense of similarities that may exist. Comparative criminology must exercise caution in examining universal similarities as some of these patterns may become unique features as new research provides us with more accurate knowledge about crime. As Braithwaite’s (1997) work has demonstrated, unique features may develop into universal patterns and concepts connected to crime across societies and vice versa. The comparative scholar must keep these problems of culture at the forefront of their research especially when it comes to drawing conclusions about their work.

This brings us to the first real problem of culture. Crimes vary by society due to what the cultural values of that society are. For example, even in the U.S. the issue of prostitution shows that we have different cultural values. In parts of Nevada prostitution is legal. Gambling is illegal in many states but not all. On a global scale the possession of drugs is viewed differently, Germany for example legalized possession and use of personal use amounts (usually less than one ounce) of several drugs within the last decade. In the U.S. even in our own history, our values regarding the use of alcohol and drugs have changed. The point is that if our own society has changes in cultural values that make an activity illegal or legal, the problem we will have when it comes to examining crime on an international scale becomes even more complex. One such issue is that in some countries, sex with children is not against the law because it is not considered an abnormal act. Given that some societies see childhood ending much earlier than 18, our cultural values create crime where it does not exist in other cultures. While the emphasis on values in criminology focuses on “bad” behavior, we must remember that values include both “good” and “bad” behavior. Further, we must acknowledge that cultural values exist on a continuum with some behaviors being seen as being worse or better than others.

Our criminal justice system expresses these cultural values. We place great emphasis on violent crime and drug related crime but far less emphasis on white-collar crime. This makes crime rates as much a product of cultural values as they are the actions of individuals. The incentive for law enforcement in the U.S. to use traffic violations as a reason to search for drugs is heavily influenced by the “War on Drugs” and specifically the financial seizure laws used to confiscate vehicles and property from drug dealers. This financial warfare has also been applied to the issue of international terrorism but not domestic terrorist groups. Given that our society is based on capitalist values it is not surprising to find that we punish and deal with white-collar criminals differently. The problem of culture raises the issue of ethnocentrism and cultural relativism. Ethnocentrism defined as the act of judging another culture based on preconceptions found in values and standards of one’s own culture (Omohundro 2008). Recognizing that we cannot simply rely on the belief that our solutions in the U.S. are the “best way to do things”, the challenge will be dealing with the issue that culture poses for us in this area. In the U.S., public opinion regarding the criminal justice is largely supportive despite a variety of problems being seen as pervasive. This often contributes to the idea that the U.S. criminal justice system is the model of best practices despite its problems (American Bar Association, 1999). The U.S. is not alone in this belief of possessing a satisfactory criminal justice system even in the face of documented problems (Nicholas, Povey, Walker, and Kershaw, 2005). An ethnocentric viewpoint to any problem facing a society can prevent changes and solutions from occurring to address those challenges. Being critical of society is often frowned upon because it violates ideas of being patriotic. Improvement is not sought out in these cases because the current approach is deemed the “best practice”. We should be careful to remember that “best practice” does not mean “only practice” or that alternative approaches do not possess a utility or value, something that ethnocentric views often ignore. The challenge becomes balancing pride in our system with the motivation to learn from different cultures to allow for the discovery of opportunities to improve our crime problems in the U.S. This can be done without a loss of satisfaction in our system if we view our system as being capable of improvement so that it continually gets better than it is.

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This is of special importance given the American emphasis on pragmatism and that knowledge, especially in the scientific arena should have practical applications (Moyer, 1992). The concern with practical applications permeates and shapes criminology in the U.S. and the nature of research into crime problems. Perhaps then it is no surprise that criminal justice practitioners in the U.S. often see criminology as being purely academic as well as being linked to the devaluation of undergraduate degrees in criminal justice in general. Further, criminal justice research in the U.S. has come to focus on practical crime problems. As a result, some solutions that we may discover through comparative criminology to issues may not work in the U.S. because of our cultural values and vice versa given the emphasis on application as opposed to theoretical concepts. The challenge for us is to recognize our ethnocentrism and be openly critical of our society to understand why crime appears in the forms that it does as well as the way it shapes the response to crime. While being careful to judge other societies’ responses as being different and not necessarily better or worse than our own in the U.S. we must also consider the limits to cultural relativism. To do this effectively we must be honest about what we are trying to achieve with criminal justice policy and approaches. If the goal of incarceration is to promote deterrence but our correctional system sees two of three individuals released from prison return within three years, then we must critically assess how successful our punishment of crime is working. This does not mean we go to an extreme and say that any cultural response to a crime problem is appropriate. Cultural relativism is the understanding that a person’s beliefs, values, and practices exist in that person’s own culture, rather than a comparison against the criteria of another (Boas 1887). To examine these cultural differences in crime and criminal justice with objectivity is certainly a noble goal however we should acknowledge that not every approach will be appropriate to be adapted either into U.S. society or conversely to take a U.S. policy and expect it to work in the same fashion in another nation. Nor should this be the goal of comparative criminology. As scholars, we must examine our own morality and be careful to suggest that behaviors such as sex with minors may ever be culturally appropriate. Rather that there may have been environments where this was not seen as criminal behavior and how these conditions were brought into existence and whether change is possible or even desirable both from within the culture or from without. One example of this comes from the issue of female genital mutilation. The basis of this outrage stemmed from Western understandings of the practice of female genital mutilation. However, successful change of the practice based on internal work done within the cultural framework of nations where it was practiced focused on the use of common values that illustrate the practice is inconsistent with other values in the society as can be seen in Ethiopia (Yee 2017). Similar approaches used within Islam to address extremist ideologies as scholars such as Mahmoud Sadri advocate that confronting the corruption of Islamic beliefs to support terrorism require the use of the culture to inform itself regarding change as opposed to the values of outsiders. This also can help to resolve some of the conflict between colonialist approaches by Western scholars regarding their criticism of practices in various non-Western cultures. The primary moral concerns of any society will be influenced by various social institutions such as religion and other moral codes imbedded in the culture and subsequently influence how a society responds to criminal behavior through social control (Fiske et al. 1998).

Figure 1.7: Cultural relativism

Another issue comparative criminologists must take into consideration is the problem of culture as aconcept. Culture isdefined as learned information which is passed from one individual to another in the context of one generation teaching a new generation the socially constructed symbols of their society (Nolan and Lenski, 1999). This definition of culture is separate from behavior and is rather based onsymbolic, socially constructed interactions between people. Symbols are used to communicate information through structure and meaning which has developed within a social collective. The application of culture as a concept can become so broad as to overshadow unique features. For example, to speak of Western or Asian culture invokes several generalizations about the nations we associate with these terms that ignores real differences between Japan and China or the U.S. and Great Britain. Further, even within one nation there are vast cultural differences based upon social class, region, and any number of social factors that comprise what we think of as culture. Therefore, internal differences are common in all societies with a foundation existing based on symbols.

Culture forms patterns of interactions between individuals in a society. These patterns exist as social expectations both within the mind of an individual when they interact with others, allowing the individual to see who conforms to and who violates are cultural expectations, as well as existing in the social structures of a society (Hofstede, 1994). These cultural patterns which emerge then serve to establish the acceptable limits of behavior within a society (Poortinga, 1990; 1997).

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Figure 1.8: Culture

Comparative criminology then must then focus on a systematic approach to integrating culture in a meaningful way into research. To do this, scholars can test criminological theories in other cultures, but they must be aware of the limits of the theory and be cautious to not over generalize their findings. Secondly, examining variations of crime and social control is another key aspect of studies in comparative criminology. Finally, a commitment to improving the quality and breadth of data available for study is also required. To effectively incorporate culture into comparative criminological studies we must be prepared to use a variety of research strategies not simply a reliance on just a quantitative or qualitative approach but rather mixed-method designs. This means that culture should be approached as a complex concept with multiple dimensions for researchers to include in their studies. The complexity of this approach however poses challenges for researchers in terms of resources. As a result, studies which approach culture in a singular trait approach are also valid. In the single approach method, a cultural trait such as religion may be seen as the most important influence on a particular view regarding a crime problem. Both approaches are relevant and provide valuable information for the examination of crime problem, allowing multi-dimensional approaches to examine patterns while also allowing for more focused approaches to focus on processes of crime.

The testing of criminological theories in different cultures helps to establish the foundation of knowledge in comparative criminology as well as determining successful programs of crime control and prevention. It should be noted that factors associated with increasing crime may produce vastly different outcomes in other cultures. This is an issue rarely faced in some disciplines that focus on causality. However, the correlates of crime are not uniform even within one society and especially not when we consider cultural differences and the interaction of multiple factors that represent the complexity of the lived social reality of any nation. Limitations then to theories will emerge which will require either the revision of the theoretical perspective to account for these differences in international context or acknowledgement of the limited utility of a theoretical perspective outside of the society and cultural context within which it was developed.

Another challenge for comparative criminologists concerns the stability of cultural patterns within a society. Generational replacement theory for example suggests that a society changes slowly as new generations are born and experience their society in different ways from older generations. This process may have taken place in a gradual sense if we only concern ourselves with the births and deaths of the inhabitants of a society. However, in our globalized world such issues as the reality of migration bring cultural changes that intertwine with the emergence of new generations. In the United Kingdom for example a once relatively homogenous and traditional society has seen various cultural changes in recent decades brought about my migration. Immigrants from India have contributed in numerous ways to the U.K. especially in cuisine. The emergence of Indo-British food has resulted in the replacement of fish and chips as the top British food; tikka masala now holds the title. The merging of Indian and British cuisine has contributed to the emergence of entirely new dishes such as the infamous vindaloo. Migration also brings changes in crime patterns as can be seen from various waves of immigration in the U.S. Organized crime groups may also emerge from conditions associated with migration of immigrant groups as seen with the Italian Mafia, Russian Mafia, and MS-13 (Arlacchi 1986).

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Conclusion

Comparative criminology seeks to move criminology beyond the dominant ideas developed by Western criminologists. Many important ways of thinking about crime and criminal justice exist around the world and can be found in Latin America, Asia, and Africa. As crime problems continue to be transnational the need for more research from criminologists from every part of the world only grows. While specific regional expertise will also be needed for crime problems unique to any specific society, for those crime problems that cross national boundaries, more complex and nuanced information will be needed.

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Comparative Criminology
Key Concepts
Medium
The study of crime and criminal justice systems across different cultures and nations. Focuses on cross-national examinations and understanding variations in crime rates and justice approaches.