System of ensuring the economic security of the state: world experience and ways of its reform in Ukraine

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National academy of internal affairs

Department of criminal law

Sumy state university

Department of administrative, commercial law and financial and economic security

System of ensuring the economic security of the state: world experience and ways of its reform in Ukraine

S. Cherniavskyi

O. Dzhuzha

V. Babanina

Yu. Harust

Kyiv, Sumy, Ukraine

Abstract

The relevance of the study: The relevance of this article is due to the fact that ensuring economic security is a guarantee of stable growth of the state and improving the welfare of the population

The purpose of the study: The purpose of the article is to conduct research on the legal basis for the functioning of economic security of the state and the activities of law enforcement agencies in the field of economic security. Research methods: Leading research methods are general scientific and special research methods, including methods of logic, analysis, comparison, etc.

The results of the study: The results of this study are a comparative legal analysis and determination of a proposal to implement the positive experience of EU countries in the field of ensuring the economic security of Ukraine. Practical significance of the study: The significance of the obtained results is reflected in the fact that this study can serve as a basis for outlining future changes to the current legislation of Ukraine on effective economic security of Ukraine

Keywords: economic security, the system of economic security of the country, law enforcement agencies, the introduction of world experience

Анотація

Система забезпечення економічної безпеки держави: світовий досвід та шляхи її реформування в Україні

С. Чернявський, О. Джужа, В. Бабаніна, кафедра кримінального права, Національна академія внутрішніх справ; Ю. Гаруст, Кафедра адміністративного, господарського права та фінансово-економічної безпеки Сумський державний університет, Україна

Актуальність дослідження: Актуальність даної статті обумовлена тим, що забезпечення економічної безпеки є запорукою стабільного зростання держави та підвищення добробуту населення. Мета дослідження: Метою статті є проведення дослідження правових засад функціонування економічної безпеки держави та діяльності правоохоронних органів у сфері економічної безпеки.

Методи дослідження: Провідними методами дослідження є загальнонаукові та спеціальні методи дослідження, у тому числі методи логіки, аналізу, порівняння тощо.

Результати дослідження: Результатами даного дослідження є порівняльно-правовий аналіз та визначення пропозиції щодо реалізації позитивного досвіду країн ЄС у сфері забезпечення економічної безпеки України. Практична значимість дослідження: Значущість отриманих результатів виражається в тому, що дане дослідження може послужити основою для окреслення майбутніх змін до чинного законодавства України щодо ефективної економічної безпеки України

Ключові слова: економічна безпека, система економічної безпеки країни, правоохоронні органи, впровадження світового досвіду

Introduction

It is worth agreeing with the majority of scholars that economic security is the basis for the functioning of a state where the latter is aimed at ensuring the protection of national interests, both internally and externally, directly in the economic sphere. And the ability to maintain resistance to external and internal threats is the so- called economic security criterion, which will ensure economic stability and independence, as well as economic growth. On this basis, we can define the main functional purpose of economic security as maintaining economic independence and increasing competitiveness in the sphere of economy, which, as a consequence, gives impetus for the future development of the country as a whole. In this regard, economic security should be considered not only as a state of protection of national interests, but also as the availability and ability to use tools to influence economic processes to ensure prosperity in the long term [1]. This strategic approach is a must, since only government action on long-term security can guarantee it [2].

The problem of effective security of economic security of the country arose in the early XVIII century, during the birth of capitalist relations and related to the security of economic entities. J. Rousseau wrote in the treatise “On the Social Contract” that the concern for self-preservation and security is the most important of all the state's concerns. At that time, security was understood as the state, the situation of rest arising from the absence of real danger, and the presence of a material organizational structure that contributes to the creation and maintenance of this situation [3; 4]. There is no need to prove that economic security is a component of the national security of the state, but nevertheless it has its structure with its own constituent elements. The question of such constituent elements is somewhat controversial, since some elements of the national security structure belong to the structural elements of economic security, thus creating a basis for scientific understanding of this issue.

Until recently such a concept as “economic security” was practically not used in legal and economic sciences and, moreover, did not attract enough attention from domestic scholars. However, the rapid development of liberalization and integration processes has led to the development of national security concepts in many countries around the world, the basic element of which its economic component [5; 6; 7].

Some scholars believe that the term “national security” was first used by the President of the United States T. Roosevelt in 1904 [8], when he justified the military action in the area of the future Panama Canal by the interests of national security, and for the second time it was used in 1934 [9]. After these speeches the world science began to actively study the national security of the country and its components. Scholars in the early XX century proved that one of the main elements of “national security” is the economic security of the state. However, the term “economic security” gained official status only in 1985, when the 40^th session of the UN General Assembly adopted a resolution “International Economic Security” [10], and the emergence of a new science - economic security - H. Pasternak-Taranushenko [11] connects with the energy crises of 1973 and 1979.

That means, that the problems of ensuring economic security in the world as a whole, and in Ukraine in particular, became the subject of research only at the end of the XX century. However, successful policy in the financial and economic sphere directly affects the economy, political and social stability of Ukraine [12-14]. Therefore, ensuring the economic security of the state is one of the urgent problems of our time.

Materials and methods

In the process of studying the system of economic security of the state, the following methods were used: general theoretical (analysis, synthesis, specification, generalization, method of analogy, modelling); empirical methods (study of the experience of law enforcement agencies to ensure financial and economic security in Ukraine and the world, study of legal-regulatory and scientific-methodological literature on this issue, scientific research and conclusions). The following scientific methods also became the methodological bases of this research: formal-dogmatic method by means of which the concept of the maintenance of state's economic safety system is outlined and features of its functioning are defined; system-structural method, which was the basis for building such a system of economic security; comparative-legal method was used in the process of studying the foreign experience of the functioning of state bodies of economic security of the world's leading countries.

In conditions of financial and economic instability in Ukraine, there are significant obstacles to the realization of economic interests in the implementation of European standards. Today, the domestic economy has not yet managed to create an effective national economic system that could ensure the progressive development of the state and strengthen the levers of foreign and domestic policy in our country. Unfortunately, national economic priorities have not yet been clearly defined, without the implementation of which it is impossible to create a European-integrated society. A thorough analysis of the European experience of forming and ensuring the economic security of the state unequivocally testifies to the need to improve the domestic mechanism for ensuring the economic security of Ukraine, in particular by introducing the positive features of globalization for the purposes of social development of the state and paying special attention to ensuring the realization of national economic interests in the process of forming the main priorities of foreign and domestic policy.

The involvement of European experience in supporting the financial and economic security of Ukraine is quite relevant in our country, because it affects all sectors of the national economy, business, all segments of the population, society and the state as a whole. Given it into account, in our research we focused primarily on the study of economic and legal mechanisms for ensuring the economic security in developed countries, because the economic security of the country in the face of globalization and global integration processes should be considered at the national and world economies. But at the same time, we should not forget about security at the level of enterprises and industries, because without the financial security of individual enterprises and industries it is impossible to guarantee the financial and economic security of the country [15; 16]. The generalization of foreign experience shows that ensuring economic security in the national economy significantly affects the international prestige of the country. In this regard, the application of the positive experience of foreign countries to ensure it should be one of the most important directions in the strategy of long-term development of the national economy of any country.

Results and discussion

Ukraine is a relatively young independent state, as quite a little time has passed since its independence. During this period the state has undergone significant transformations, in particular, abandoned the planned economy with its command-and-control methods and created its own national economic system on a market basis, in addition, formed the basic foundations (on which, in fact, independence and sovereignty of the state rely) of the national policy in all the most important spheres of public life. It is also impossible to avoid the fact that during the years of independence Ukraine has gained international recognition as a full-fledged subject of the world community and has significantly established itself in this status. This, in its turn, had a significant positive impact on the level of its independence, sovereignty and national security, including economic security as one of its main components [17].

In connection with the change in the principles of functioning of the country's economy and the movement of financial flows, the issue of creating and functioning of an effective system of economic protection of Ukraine in the state has become extremely important. Studies of leading systems of economic protection do not give a specific answer which of them is suitable for our state. The Ukrainian mentality, the Soviet past and the constant change of Ukraine's political course prove that it is necessary to build its own national and unique system of protection of the country's economy. In our opinion, this should be the only central executive body that will be fully responsible for ensuring the economic security of Ukraine and the state of economic crime. It should include both a supervisory (fiscal) function and law enforcement, and its activities should be based on in-depth economic and criminal analysis of the activities of economic relations.

The establishment, main activities and delineation of the role and place of such a new law enforcement body are provided by the Memorandum on Economic and Financial Policy, approved by the IMF Board of Directors on December 18, 2018 [18]. After all, it is planned that this entity will be endowed with a wide range of powers, including ensuring the economic security of the state. It should also be noted that Ukrainian society and the international community expect from this law enforcement agency the effective results in counteracting many threats to the country's economy.

In the context of reforming the sphere of financial and economic security of the state, scientists have developed a concept of reforming government agencies to ensure effective protection of Ukraine's economy. It was developed within the framework of the project of the Ministry of Education and Science of Ukraine “Concept of a New Innovative Model of Public Administration of the Financial System of Ukraine” No. 0118U003582 (55.16-01.18/20. ZP). The concept lays the foundations for creating a clear responsibility for ensuring Ukraine's economic security and combating economic crime, as well as making it possible to significantly reduce the manifestations of corruption in law enforcement and regulatory agencies. The proposed Concept provides for the optimization of the structure of law enforcement and regulatory agencies by: reforming the structural units of law enforcement agencies with a clear definition of tasks and functions to ensure economic security; elimination of duplication and parallelism in the activities of individual law enforcement agencies, as well as the involvement of employees to perform functions not inherent to them; optimization of the number of controlling bodies that carry out documentary inspections of business entities; creation of a single state service of economic security of Ukraine with the definition of optimal and reasonable staffing and structure.

The functioning of a single law enforcement agency that will ensure financial and economic security in the country is extremely relevant and controversial. Neither in scientific doctrine nor in the practical sphere has a unified vision of the administrative and legal nature of such a body been developed. In particular, V.S. Chuban and K.M. Pasynchuk emphasize that the task of the new law enforcement agency should be identification and elimination of the systemic threats in the field of public finances and preventing their occurrence in the future. Such a body should act as a single analytical centre for analysis and concentration of information on the general state of functioning of the financial system of the state. In addition, scientists point out that the key task in the work of the body should be to build a basis for the transition of state regulatory authorities from supervisory and punitive model of work and performance of powers to the preventive and service one [19].

I.B. Bezzub generally compares the functioning of the future body with the “intellectual centre, whose work will be based on the use of modern risk-oriented methods of criminal analysis” [20]. In addition, the work of this body should be based on the OLAF methodology - the latest law enforcement methodology, which is guided by analytics, which involves collecting information from clearly identified sources, its accumulation in the risk management system and further analysis to fully identify risks and threats to Ukraine's financial security [19].

O.P. Riabchenko, V.Y. Matsyuk, G.V. Solomenko in their research predict that the new law enforcement agency, whose activities will be aimed at ensuring the financial security of Ukraine, will be of European standard and will act as a guarantor of such security, will combat financial crimes, will ensure the return of shadow financial resources to the legal channel, will take measures to de-shadow the economy. The basic tasks should be: prevention of fraud in the field of public finance, the formation of legal awareness and legal culture of citizens on the voluntary payment of taxes and fees, namely taxation should become a custom, and not to be carried out under the influence of harsh coercion [21]. However, there is a question about the legal support of this body, its place in the system of economic security of the country and in the system of state bodies in general. If this body is established, the existing model of economic security in Ukraine will completely change. That is why the experience of the world's leading countries in legally ensuring the functioning of various models of economic protection of the country is extremely important.

Revealing the experience of the European Union in general, it should be noted that the creation of an effective system of economic security has a decisive influence on the assigning a clear place for a particular European country in the global world, which would correspond to its geostrategic significance and potential. That is why today the implementation of the positive experience of EU countries in building and functioning of an effective economic security system should become one of the priorities of Ukraine's foreign policy not only in terms of achieving stability and efficiency of the national economy, but also in terms of long-term national development strategy. The European Union was created half a century ago as a union of states capable of ensuring the economic security of Western Europeans after the Second World War. It is thanks to its “social core” and well-thought-out strategy in the field of socio-economic policy that the EU has managed to achieve internal stability and deepen integration, including economic integration among the member states of the union. Its progressive expansion is not directed against any states, but is a sensible way to achieve security through cooperation. It is also linked by various treaties with many countries [22]. In this context, the intention set by the European Council in the Green Book to create a “dynamic and efficient European security market” based on progressive business circles and companies “with a strong social and environmental base” aware of their social responsibility is quite significant [8]. Indeed, supporting such zones leads to the formation of common living standards, strengthens mutual trust and allows the EU to be seen as a prototype of the security community.

International organizations created after the Second World War, such as the United Nations, the Council of Europe, NATO, and WTO, presented themselves to the people of their member states as certain guarantors of security. Thus, on the European continent, the basis for the formation of a homogeneous social space capable of becoming a guarantor of stability as the only pan European security organization was the Organization for Security and Cooperation in Europe (OSCE). Given the existing capacity to maintain stability in Europe and the world, the OSCE acts as a legitimate guarantor of European security. Most EU countries define the strengthening of the European stability area through the development of European integration and an active neighbourhood policy of the European Union with the countries of Eastern Europe, the South Caucasus, Central Asia and the Mediterranean region as the main task of security policy in national doctrines. However, in our view, the concept of economic security of the European Community must be considered to a large extent in the context of the economic security of each individual state, national doctrines, programs and concepts of national security.

Thus, Germany sees ensuring its economic security in support of economic and social progress, democratization in Europe and around the world, protection from economic blackmail, ensuring freedom of trade and access to raw materials and markets within a fair world economic system. Under domestic economic plans, the goal is to guarantee the healthy economic development of the country, material and social well-being of the population. In foreign economic terms, the main emphasis, given the export orientation of the economy, is on the stability and improvement of markets. It should be noted that in Germany there is no separate law on the concept of economic security. The state philosophy of economic security in practice is implemented mainly through laws that regulate the most important areas of market activity and give the state significant control functions [23]. To protect the financial and economic interests of the country and the fight against economic crime, the German tax authorities have created a specialized unit to combat economic crime - the tax investigation service “Steufa”, which reports to the Ministry of Finance. This unit was formed in Germany in 1934. Employees of the tax investigation service “Steufa” have a special legal status, which allows them to perform the main tasks of protecting the financial and economic security of Germany, namely:

- determination of the tax base in the detection of tax crimes;

- investigation of tax crimes;

- detection and investigation of tax crimes where the identity of the offender is not established.

To perform these tasks, employees of the tax investigation service “Steufa”, being on duty in the financial authorities, are also freelance employees of the prosecutor's office, which allows them to conduct appropriate investigative actions. However, the main methods of ensuring the safe development of the economy in Germany are actions to maintain the civilized nature of market relations, creating equal conditions for competition, preventing monopolization in certain industries and maintaining the stability of the national currency. Financial and economic security policy in the UK is closely linked to defence policy: both are based on assessments of national interests and are implemented through their protection. Under the “national interests” in the economic sphere are understood the economic interests of society as a whole, which have priority over other forms of public interest [12].

Thus, threats to national economic security are divided into external and internal and are ranked according to the degree of importance and probability of occurrence, which allows concentrating efforts on forecasting and preventing the most dangerous, in terms of national economic security, risks. According to the British political elite, the external threats to national security include: international terrorism in all its manifestations; cyberattacks; production of weapons of mass destruction (nuclear, chemical, biological) and means of delivery; man-made disasters and emergencies; natural disasters and natural disasters of various kinds. The list of internal threats includes: location and degree of tension between the main political forces; the orientation and nature of the activities of nationalist and separatist groups; political and religious extremism; criminalization of public relations. These may also include the state of affairs in science, economics, social sphere, energetics, climate change, globalization of migration, urbanization and a number of other factors [24].

It should be noted that in the field of preventing economic threats the government traditionally rely on private business, providing it with maximum support. In addition, the country has an extensive network of institutions that ensures effective interaction between parliament, government and big business in the development and implementation of decisions related to national economic security [25]. It includes, in particular, organizations such as Confederation of British Industry, East European Trade Council and a number of more specialized organizations representing the interests of industrialists and entrepreneurs. There is no special legal framework for ensuring financial and economic security, and some of its provisions, as noted above, are contained in regulations in the field of defence policy. Methods for ensuring the financial and economic security of the United Kingdom are primarily related to forecasting and preventing the most dangerous external and internal risks.

The UK has an effective system of economic security based on an extensive network of institutions that ensure the interaction of parliament, government and business in the development and implementation of decisions in the field of national economic security. Such influential institutions include Confederation of British Industry, East European Trade Council, and other more specialized organizations representing entrepreneurs [26]. The initiative of the British government to establish a National Crime Agency is of particular note (The National Crime Agency). It consists of a number of commands, one of which will deal with economic crime. The National Criminal Agency is not the UK's new separate law enforcement agency. It acts as a managerial and operational unit within the Ministry of the Interior. The purpose of its activities is to integrate the efforts of existing law enforcement agencies in the performance of specific functions, in particular to combat national economic crime, and to supplement these forces with new critical tools such as intelligence and specially trained operatives [27].

In its turn, in France the main state document, in which certain provisions of economic security are affected, is the Law “On National Security” dated 1964 [28]. The concept of national economic security in France is interpreted as the creation of favourable internal and external conditions to increase national welfare and strengthen the country's economic potential. Economic security in the broadest sense is provided by the whole set of tools of economic regulation. For this purpose, in France in the process of making and adoption of economic decisions, criteria related to reducing the vulnerability of the economic system and preservation of the economic foundation of an independent foreign policy are used. Such criteria include: elimination of serious disparities in the level of economic development of economic entities; prevention of excessive external dependence in the most important sectors of the economy: minimizing the risks associated with dependence on the outside world [25].

In France, tax investigations are carried out by the police, the tax service carries out only administration, the customs service has its own law enforcement powers, and financial intelligence is the responsibility of the Ministry of Finance [27]. The long-term process of finding effective ways to reliably protect national economic interests in the United States has created an effective and efficient regulatory framework for economic security [29; 30]. US economic security, as a separate and holistic issue, is not formulated in conceptual and strategic documents, as well as in laws and regulations. It is considered only as an integral and most important of the structural components of the national security of the United States in the National Security Strategy and is presented as separate aspects of its provision in the laws [31].

The principles of ensuring the country's security are enshrined in the official act of the United States - the National Security Strategy. According to this document, the national interests of the United States are classified according to the level of importance for the country into three categories: the first group is vital interests; the second group - important interests; the third group - humanitarian and other interests. Economic interests are part of the first category of importance of the national interests of the United States, the provision of which is an unconditional priority of the national security policy of the United States, for the protection of which the US government must do everything possible even through unilateral use of force. These include: the economic well-being of society and the protection of vital public infrastructures, including energetics, banks, finance, public communications, etc. [32]. The main directions of US national security policy are presented in the National Security Strategy in three main areas: the formation of a secure international environment in America, ensuring an adequate response to threats and crises, proper preparedness of American society for unpredictable tendencies and phenomena in the future. Every area provides measures to address economic security issues [17].

In the United States tax crime is controlled by the Internal Revenue Service, which is part of the Department of the Treasury. Internal revenues include the investigative department, which is responsible for investigating tax offenses and crimes, as well as all violations of the law on banking secrecy [33]. The Italian Republic has a powerful paramilitary law enforcement agency specializing in all types of economic crimes [27]. The state is characterized not only by strict centralization of law enforcement activities, but also by the traditional use of the national police and gendarmerie.

The functioning of a single law enforcement agency that ensures the financial and economic security of the state for foreign countries is not a novelty. In particular, the Financial Guard of Italy is the oldest military police corps in Italy, which existed in the XVIII century under the Kingdom of Sardinia, and its predecessor can be considered the “Legion of Light Troops”. The Financial Guard (Guardia di Finanza) of Italy is administratively subordinated to the Ministry of Economy and Finance. The financial intelligence body is subordinated to the same ministry, but it is not part of the structure of the Financial Guard. This model has more than a century of history. It reflects the Italian experience of state building and the peculiarities of the geographical location of the country [27].

The scope of the Financial Guard application is quite wide - it is the protection of national and European financial interests, the cessation of tax crimes, the fight against organized crime, smuggling, counterfeiting of goods and banknotes, illegal building activity, drug trafficking and money laundering, combating illegal immigration, termination of Internet fraud, gambling control, taxation of individuals and legal entities. The Financial Guard of Italy thus performs the functions of the tax police, the tax inspectorate, the customs and the border authorities at the same time. The Italian Financial Guard is not authorized to apply punitive measures on its own. If a crime is detected, an investigation is conducted and its materials are passed to the prosecutor's office. Tax violations that do not fall under the category of crimes are transferred to the tax service, and it accordingly applies administrative penalties, such as fines [20].

The model of activity of the Financial Guard of Italy, which centrally counteracts financial and economic offenses, is also followed by Romania and Macedonia. In particular, in Romania the Financial Guard of Romania, which reports to the Ministry of Economy and Finance, is responsible for monitoring compliance with tax laws, preventing, detecting and investigating tax evasion and tax fraud. The Financial Guard of Romania is headed by the Commissioner General, who carries out financial control and inspections of compliance with regulations in order to prevent, detect and stop actions prohibited by law, trade rules to prevent, detect and eliminate illegal trade, production, storage, movement and sales of goods in the state.

In Macedonia, the Bureau for the Investigation of Financial Crimes, which protects the financial and economic interests of the state from unlawful encroachments, is also subordinate to the Ministry of Finance. This law enforcement body is responsible for performing such functions as: ensuring financial control, control over the application of tax, customs and other rules in the field of finance; detection and documentation of criminal cases in the field of combating organized financial crime; carrying out preliminary investigative actions to detect and ensure the recording of traces of the crime, etc. [34]. The Financial Police also operates in Croatia, but structurally it is part of the Ministry of Finance and is headed by a Chief Inspector, who is appointed by the government on the recommendation of the Minister of Finance. The Austrian Financial Police is a special unit of the Austrian police to combat tax fraud related to the concealment of tax revenues and social security contributions. To identify the facts of tax evasion, social security contributions, the facts of the shadow economy, the Austrian Financial Police has the right to conduct targeted inspections [35].

In Spain, a Tax Agency has been established on the basis of the Ministry of Economy and Finance, the main task of which is to plan the activities of tax authorities, to carry out national measures to control the legislation in the field of taxation, etc. In its structure, the units for combating tax fraud (most often related to value added tax) have been formed [17]. The Norwegian National Office for the investigation and prosecution of economic and environmental crimes has a dual legal nature and functions both as a central body for economic and environmental investigation and prosecution and as a special department of the police and prosecutor's office. In fact, this body is subordinated to the Police Directorate and the Prosecutor's Office Directorate [35].

The models that can be proposed based on the results of studying the experience of the European Union, can be effective in Ukraine not only theoretically but also practically. The implementation of the experience of the European Union in the context of the transformation of the world economy today is the most pressing issue of cooperation in the framework of the Ukraine-EU partnership program. Based on the experience of European countries, including the new member states of the European Union, Ukraine must form a new ideology of security, the core of which is the achievement of the sustainable economic development by performing certain tasks and obtaining concrete results based on efficient use of resources, compliance with legislation and current developed legal documents [36]. law enforcement economic security european union ukraine

Obviously, the implementation of the “best” models must be timely and carefully calculated. As the analysis of the experience of the new EU member states shows, that it is very important to avoid mechanical copying of the practices of other countries, which could lead to a reduction in the capabilities of national security structures. Ultimately, the successful provision of national economic security by the countries of the European Union depends on the stability and strength of their national economies. Only a strong economy can successfully protect national interests in conditions of increased global competition and growing global economic imbalances [37]. Highlighting the proposals to implement the positive experience of EU countries in ensuring the financial and economic security of Ukraine, it should be mentioned that the EU dictates the importance of European integration to achieve a high level of competitiveness in the context of globalization. The ultimate goal of the EU is to ensure economic security and the formation of a fully integrated Europe with the same standard of living in all member states [38].

Having studied the models and experience of the world's leading countries in creating an effective system of economic security, we can note their diversity both in terms of legal support and in terms of the organization of the structure itself. The experience of forming the economic security of the United States of America attracts our attention. Thus, the national interests of the United States are defined by the National Security Strategy, which is classified according to the level of importance for the country into three categories: vital interests; important interests and humanitarian and other interests. Economic interests are part of the first category of importance of the US national interests, the provision of which is an unconditional priority of the national security policy of the United States, for the protection of which the US government must do everything possible, even through the unilateral use of force. These include the economic well-being of society and the protection of vital public infrastructures, including energetics, finance and public communications [39]. The main directions of the US national security policy are determined by the National Security Strategy in three main areas: the formation of a secure international environment in America, ensuring an adequate response to threats and crises, proper preparedness of American society for unpredictable trends and phenomena in the future.

In the United Kingdom the security policy is also closely linked to defence policy, based on assessments of national interests and is implemented through their protection. Under the national interests in the field of economy the economic interests of society as a whole are understood, which have priority over other forms of public interests [29]. In the United Kingdom, threats to economic security are also divided into external and internal, according to the degree of importance and probability of occurrence, which makes it possible to distribute efforts and prevent the most dangerous of them in terms of national economic security. In this area, the government has traditionally relied on private business for maximum support, and the country has a well- developed system of institutions that ensures effective interaction between parliament, government and big business in the development and implementation of decisions related to national economic security [25].

On the contrary, in Germany there is no separate law on the concept of economic security. The state philosophy of economic security in practice is implemented mainly through laws that regulate the most important areas of market activity and give the state significant control functions, and the main interests of the state in national security, including its economic component, presented in the form of an official directive of the German Ministry of Defence [23]. In fact, economic security is based on economic and social progress, protection from economic blackmail, ensuring freedom of trade and access to raw materials and markets within a fair world economic system. The main methods of ensuring stable and safe development of the economy in foreign economic terms are the actions of government agencies and businesses to improve markets and focus on the export economy [17]. That means, that economic security in a broad sense is provided by the whole set of tools of economic regulation. In the process of developing and making economic decisions, criteria related to reducing the vulnerability of the economic system and preserving the economic foundation of an independent foreign policy are used. Such criteria include: elimination of serious disparities at the level of economic development of economic entities; prevention of excessive external dependence in the most important sectors of the economy; minimizing the risks associated with dependence on the outside world [40].

The analysis of the experience in ensuring the economic security of Western European countries such as the Netherlands, Belgium, Denmark, Luxembourg, Switzerland, shows that their main strategic goal to protect national economic interests is to ensure sustainable economic growth and economic modernization depending on competition in the world market [38]. Taking into account the national definitions of “economic security” and definitions in the legal systems of the above countries, we can conclude that the economic security of the state is the main component of national security, which contributes to the protection of national and state interests in the economy, the main criterion of which is the ability the country's economy to contain internal and external threats [41]. It is necessary to note that in France the main state document, which affects certain provisions of economic security, is the National Security Act of 1964. The concept of national economic security is considered by this law as the creation of favourable internal and external conditions for increasing and developing national welfare and strengthening the economic potential of the country [28].

In the Czech Republic the main officially recognized conceptual document on the national security policy is the Security Strategy of the Czech Republic, which identifies national interests, threats and dangers to national security and formulates the state's long-term intentions and measures to ensure peaceful development and economic prosperity. The security strategy identifies six main areas of national security: civil, public, political-military, economic, environmental, as well as the area of criminal elements and organized crime. The areas of economic policy of national security are: ensuring economic growth, economic development and international cooperation; support of internal and external stability; reduction of inflationary pressure; maintaining a positive foreign trade balance; effective market regulation in the economic and financial spheres; fight against crime [25].

In Romania the National Security Strategy was approved in 1999 at a meeting of the Supreme Council of State Security. This most important document for the country is aimed at ensuring democracy and stability in the development of the state and integration processes. The main areas of ensuring the economic security are: implementation of effective measures of macroeconomic stabilization, acceleration of structural reforms in the economy, creation of the private sector, attraction of foreign investments and support of small and medium business; harmonization of financial and economic legislation, financial, economic and customs policy with European legislation, requirements and directives of the European Union [28].

In June 2000, the Government of the Republic of Poland adopted a conceptual document on national security “The Security Strategy of the Republic of Poland”. The strategic goal of the state national security policy in Poland, in accordance with the Security Strategy, is to guarantee the independence and sovereignty, the territorial integrity of the state; creating conditions for development; preservation of national heritage and development of national dignity of Poles [42]. The main threats to the economic security of the Republic of Poland, according to this document, include threatening economic instability in neighbouring countries and the negative impact on the Polish economy, significant external dependence of the state on energy supplies from abroad, non-diversification of these sources; uncontrolled migration processes that can damage the socioeconomic stability and financial-economic capabilities of the state.

The concept of economic security is considered in Spain largely in the context of the economic security of the entire European Union. At the same time, an effective system of ensuring national interests in the economic sphere has been created. It is based on: flexible legal and regulatory framework; clear division of competence of ministries, departments and organizations in the implementation of regulations related to economic development; the presence of a legally approved program of economic priorities at each stage of development, which should exclude the possibility of targeted privileges; availability of special state control services.

Officially recognized political views on the protection of citizens, society and the state from the impact of external and internal threats to national security in the Republic of Bulgaria are enshrined in the 1998 National Security Concept. The national economic interests of the Republic of Bulgaria are the following: improving the quality and standard of living of the population, the efficiency of social and medical services in the country; ensuring state sovereignty, economic independence; achieving financial stability, a high level of economic and social development; improving the effectiveness of domestic and foreign economic policy. The threats to the economic security of the Republic of Bulgaria are: significant economic and social differentiation of countries on the continent, which threatens regional socio-political and socio-economic stability and has unpredictable consequences; the spread of international financial and economic crime, smuggling of goods; application of trade, economic and financial sanctions against neighbouring states; social instability in the state, the crisis of the national economy; lowering of living standards of the population; demographic crisis, migration processes [43].

As we can see, the policy of economic security of the Czech Republic, Poland, Slovakia and the Baltic States is based on the convergence of national interests with pan European interests, as well as political, economic and institutional transformation in accordance with Western European standards. In the early 1990s, these countries chose a similar model of ensuring the economic security, which included: assessing the geopolitical situation in the region; definition of development vector and strategy; construction and implementation of a model of behaviour, including in the field of economics, in accordance with the dominant trends of regional and global evolutionary process; the ratio of basic quantitative indicators of development with world and regional standards; correction of the course of economic reforms [40]. Comparing the interpretation of the concept of “economic security” in Ukraine and certain countries of the European Union, we can state that economic security is generally seen as part of national security, which aims to eliminate and prevent internal and external threats to ensure a sufficient standard of living, creating interaction between public authorities and private entities.

Conclusions

Foreign experience in solving problems of financial and economic security convincingly demonstrates the need to improve the conceptual support of economic security in the foreign economic sphere of Ukraine, the use of positive signs of globalization for the purposes of social development of the state and prioritize the ensuring of the national economic interests in the process of foreign and domestic policy formation. The analysis of approaches to ensuring economic security by the countries of the European Union shows that this level of security is quite high and depends on various factors. If Ukraine seeks to preserve its domestic market and independent economic future during the EU integration, it must go a long way in overcoming the economic crisis. In order to achieve it, it is important to understand the concept of the essence of economic security and authorized state bodies and structures should take clear and coordinated actions to bring the level of Ukraine's economic security system closer to the European one.

The models of economic security in foreign countries, which were discussed above, can be an effective practical example for the formation of a new ideology of national security in Ukraine, based on economic development and protection from external and internal threats, efficient use of resources and ensuring the socio-economic requirements of the population. The state should not only develop a national concept of security based on world experience, but, above all, to reform economic domestic and foreign policy in order to protect all economic entities. The results of this study can be used by scientists and practitioners for further more thorough study of the financial and economic security of the state, models of such a system and the development of innovative and strategic areas of a single law enforcement agency that ensures financial and economic security.

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