Russian and German models of voluntary compensation for damage caused by a crime

The article is devoted to the study of the Russian and German models of voluntary compensation for damage caused by a crime. The problem of voluntary damage compensation in the Russian criminal procedure is considered as a condition for terminating criminal proceedings through the prism of a comparative legal analysis of the similar institution in the German criminal procedure. Taking into account the German experience, possible options for improving the Russian model of voluntary compensation for damage caused by a crime are proposed.