AbstractThe cultural properties are complex objects of cultural, economic and investment mechanism. The acts against them appear as an interdisciplinary problem, the combat against these diverse actions can be realized by the regulations of the various areas of law. However, the threatened values, the size of the damages and the related crimes with great weight make the intervention of criminal law necessary. Italy is characterized by one of the wealthiest cultural heritages of the world. For this reason, Italy takes a leading role in fighting against actions violating these values. This protection is realized at different levels and by several measures. In addition, the Italian system is characterized by special police forces dedicated to law enforcement in this field. The Italian and Hungarian system have been examined and compared them in the field of the criminal law protection of cultural property in order to give appropriate suggestions and to make the Hungarian protection system more effective. The paper will introduce the constitutional bases, the legislation, the organization system, and practical experience in both country and compare them. With the help of this comparative analysis, it will be possible to improve the protection of cultural properties in Hungary and hopefully it will give useful advice for other countries.
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