ACCORDING TO GERMAN LAW, THE INVESTIGATIVE EFFORTS OF THE POLICE SHOULD BE HEADED BY THE PROSECUTING ATTORNEY. IN PRACTICE, HOWEVER, THE POLICE USUALLY CONDUCT THEIR OWN INDEPENDENT INVESTIGATION. ONLY UPON COMPLETION ARE THE FILES FORWARDED TO THE PROSECUTING ATTORNEY WHO THEN DECIDES WHETHER HE WANTS TO PROSECUTE. THE NETHERLANDS, AUSTRIA, AND THE U.S. (COUNTRIES WITH A COMPARABLE LEGAL SET-UP) CANNOT OFFER MODELS FOR IMITATION SINCE THEY ARE LOOKING FOR SOLUTIONS TO THE SAME DISCREPANCY BETWEEN LEGAL THEORY AND PRACTICE. AUSTRIA, FOR EXAMPLE, SEEMS INCLINED TO LEGALIZE THE ALREADY EXISTING SEPARATION BETWEEN POLICE AND PROSECUTING FUNCTIONS, WHILE FRANCE FAVORS THE COMPLETE INTEGRATION OF THE CRIMINAL POLICE INTO THE COURT SYSTEM. IN THE UNITED STATES, EFFORTS TO INCREASE THE COOPERATION OF THE TWO AGENCIES HAVE BEEN MADE. IN OTHER COUNTRIES THE LEGAL AND PRACTICAL SITUATION IS TOO DIFFERENT FROM GERMANY TO BE READILY TRANSFERABLE. NEVERLESS, BRITISH ATTEMPTS TO INTRODUCE THE OFFICE OF PROSECUTING ATTORNEY INTO THEIR LEGAL SYSTEM SEEM TO ARGUE AGAINST RECENT GERMAN ATTEMPTS TO ABOLISH THE AGENCY ALTOGETHER. IN DENMARK AND NORWAY, THERE IS A COMPLETE DIVISION OF LABOR, WITH THE POLICE INDEPENDENTLY INVESTIGATING MINOR OFFENSES AND THE PROSECUTING ATTORNEYS CONCENTRATING ON SERIOUS CRIMES. BELGIUM POSSESSES A REGULAR 'COURT POLICE' WHICH IS UNDER THE SUPERVISION OF THE DEPARTMENT OF JUSTICE. IN A FEW SWISS COUNTIES, THE CRIMINAL POLICE IS PART OF THE PROSECUTING AGENCIES. SINCE NONE OF THESE MODELS IS READILY ADAPTABLE TO GERMAN CONDITIONS, NO CONCRETE SOLUTION TO THE PROBLEMS OF THE FEDERAL REPUBLIC OF GERMANY ARE OFFERED. --IN GERMAN. (AUTHOR ABSTRACT MODIFIED)