ALMAN GÜMRÜK İDARESİ VE ZKA

1. GİRİŞ

Son 50 yıl içerisinde Batı Avrupa ülkeleri arasında gerçekleştirilen gümrük birliği ve sonrasında tesis edilen Avrupa Tek Pazarı ile birlikte iç sınırlarda kontrolün kaldırılması, topluluk gümrük mevzuatının yürürlüğe girmesi ve topluluk sınırlarının Doğu Avrupa Ülkelerine açılması, Alman Gümrük İdaresinin yeniden yapılanması sürecini de hızlandırmıştır. Son 10 ülkenin de katılımıyla birlikte Avrupa Birliği’nin(AB) doğu sınırları yaklaşık 7412 km.ye ulaşmıştır. Ağustos 2002 tarihinde yürürlüğe giren bir yasa ile gümrük soruşturma teşkilatı yeniden örgütlenmiş, bu kapsamda, 23 ana gümrük ofisi ve 216 gümrük ofisi kapatılarak maliye bölge ofislerinin sayısı 21 den 8’e düşürülmüştür. 2002 yılı başlarından itibaren başlayan “Modern Devlet-Modern Gümrük İdaresi” programı, günümüzde daha etkili ve daha az maliyetle çalışan idare hedefine çok yaklaşmış görünmektedir.

AB’nin iç sınırlarında kontrollerin kaldırılmış olması, AB vatandaşlarının rahatsız edilmeksizin gelişmiş teknoloji yardımıyla izlenmesi ve dolayısıyla ileri düzeyde bir risk analizi sisteminin kurularak güvenliğin daha da artırılması ihtiyacını beraberinde getirmiştir. Bu durum, elbette, Alman Gümrük Soruşturma Dairesi (Zollkriminalamt), kısaca ZKA’nın önemini de ortaya koymaktadır.

Tam üyelik yolunda son dönemece girmiş olan Türkiye, AB ülkelerinin ve özellikle Almanya’nın modern gümrük teşkilatı yapısını yakından incelemek ve idari uyum çalışmalarını hızlandırmak durumundadır. Bu kapsamda, yazımızda, Alman Gümrük İdaresinden (Zoll) kısaca bahsederek, bu idare içinde yer alan Alman Gümrük Kriminal Dairesi Zollkriminalamt (ZKA)’yı ayrıntılı olarak incelemeye çalışacağız.

2. ALMAN GÜMRÜK İDARESİ (ZOLL)

2.1. İdari Yapısı

Alman Federal Maliye Bakanlığı çatısı altında görev yapan ve en alt seviyeye kadar örgütlenmiş yegane kuruluş olan Gümrük İdaresi, her yıl yaklaşık 100 milyar Euro tutarında tüketim ve katma değer vergisi gelirini federal bütçeye kazandırmaktadır. Federal Devletin en büyük organlarından birini teşkil eden Alman Gümrük İdaresi, Federal Maliye Bakanlığı’nın operasyonel faaliyetlerinin yaklaşık %80’ini temsil etmektedir.

Halen, Alman Gümrük İdaresi, Federal Maliye Bakanlığı’na bağlı Gümrük Kriminal Dairesi (ZKA) ve Maliye Bölge Ofisleri ile bunların bağlantılarından oluşmaktadır.

Federal Maliye Bakanlığı’na bağlı 8 adet Maliye Bölge Ofisi, kendilerine bağlı yerel gümrük idarelerinin koordinasyonundan ve denetiminden sorumludurlar. Yerel olarak görev yapan Ana Gümrük Ofisleri, gümrük ofisleri ve gümrük komiserlikleri olmak üzere çok sayıda ofisin çalışmasından sorumludurlar.
Ayrıca, halen, yerel olarak görev yapmakta olan 8 adet gümrük soruşturma ofisi, kendilerine bağlı 24 adet şube ile birlikte doğrudan ZKA’ya bağlı olarak faaliyet göstermektedir.

2.2. Görevleri

Birey odaklı, etkinlik, esneklik ve güvenirlik esasına dayalı hizmet vermekte olan Gümrük İdaresinin başlıca görevlerini aşağıdaki şekilde ifade edebiliriz:

• Gümrük vergilerinin etkili bir şekilde toplanmasını sağlamak
• Modern yöntemleri kullanarak ticari ve ekonomik gelişmeye katkıda bulunmak
• Vatandaşları ve ekonomiyi korumak
• Uluslararası organize suçlarla mücadele etmek. Özellikle; uyuşturucu ticareti, korsan üretim, kaçakçılık, para aklama ve yasadışı para transferleri ile uluslararası türlerin korunması anlaşmasına aykırı eylemler,
• İthalat ve ihracatı düzenlenmek
• Sınır kontrol hizmetlerini sunmak
• Gümrük Soruşturma hizmetlerini yürütmek
• Gümrük müdürlüklerinin yönetimini sağlamak
• Harici muhasebe denetim hizmetleri yapmak

Ayrıca, yeşil hatta polis kontrollerinin yapılması, gümrük ve diğer idarelerin ilgili kararlarının yerine getirilmesi ve sosyal sigorta kartlarının kontrolü de gümrük idaresinin dolaylı görevleri arasında yer almaktadır.

2000 yılı AB Bütçesinin toplam 15 milyar Euro tutarındaki gümrük gelirlerinin yaklaşık 3.4 milyarlık kısmı Alman Gümrük İdaresi tarafından sağlanmıştır.

Ana Gümrük Ofislerine bağlı bulunan Gümrük İnfaz Büroları, Federal Devletin Tahsilat büroları gibi görev yapmaktadırlar. Örneğin, eğer bir yolcu tatil dönüşünde getirdiği mallar üzerindeki vergileri ödemekten kaçındığı takdirde bu infaz büroları devreye girmektedirler. Ayrıca, bu bürolar, hastaneler, ticari birlikler, iş kurumları gibi doğrudan Federal kurumlar ile Federal Hükümetin alacaklarının tahsilinden de sorumludurlar.

Öte yandan, halkın ve çevrenin radyoaktif maddelerden korunması da AGİ’nin sorumlulukları arasında bulunmaktadır.

Alman Gümrük İdaresi, firmaların yasaya uygun olarak işçi çalıştırıp çalıştırmadıklarını da kontrol etmekte ve yasadışı istihdamla mücadele etmek amacıyla Federal İş Kurumu’yla işbirliğine giderek ortak tedbirler alabilmektedir.

Diğer taraftan, eğer gümrük ile ilgili bir suç işlendiğine dair işaretler ortaya çıkması halinde, gümrük memurları olayın ortaya çıkarılması için ilk ve acil tedbirleri almakla yükümlü tutulmaktadırlar. Ayrıca, gümrük memurlarının, Savcının emriyle ayrıntılı soruşturma yapmak için de görevlendirilebilmeleri mümkündür.

Federal Gümrük İdaresi’nin çağrı merkezi olarak görev yapan Frankfurt Bilgi Merkezi, gümrük ile ilgili tüm sorulara cevap verebilmektedir.

Alman Gümrük İdaresi, insan sağlığı, kültürel değerler, bitkiler, hayvanlar, çevre, kamu düzeni, sınai hakların korunması ve savaş silahlarının kontrolü amacıyla, Federal Almanya sınırlarından geçişlerde yasaklama ve kısıtlamalar koyabilmektedir.

3. ALMAN GÜMRÜK KRİMİNAL DAİRESİ
(ZOLLKRIMINALAMT) (ZKA)

3.1. ZKA’nın Kuruluşu

Özellikle adli sahada görev yapmak üzere 1952 yılında kurulan Gümrük Kriminoloji Enstitüsü (Zollkriminalinstitut) (ZKI), 1985 yılında Merkezi Gümrük Soruşturma Ofisi’ne dönüştürülerek, kendiliğinden soruşturma yapmaya başlamıştır.

Öte yandan, Avrupa Tek Pazarı’nın teşkili ve sınırların doğu Avrupa’ya açılması ile birlikte, gümrük soruşturmalarına konu olan suç türlerinde de önemli değişiklikler olmuş, bu durum, gümrük soruşturma hizmetlerinin yeniden yapılanmasını gerektirmiştir. Bu kapsamda hazırlanmış olan, 1990 tarihli Uyuşturucuyla Mücadele Milli Planı’nın uygulamaya geçirilebilmesi için, gümrük soruşturma hizmetleri personel ve kaynak açısından geliştirilmiştir.

Mali Yönetim Kanununda ve Diğer Kanunlarda Değişiklik öngören ve 15 Temmuz 1992 tarihinde yürürlüğe giren Kanun ile, ZKI’ın (Zoll Kriminal Institut) yerine yeni bir Gümrük Kriminal Dairesi oluşturulmuştur.
Zollkriminalamt (ZKA) adını alan bu yeni Merkezi Gümrük Soruşturma Örgütü, ZKI’nın yerini almış ve yeni görevlerle birlikte ZKI’nın tüm görevlerini üstlenmiştir.

3.2. ZKA’nın Yeniden Yapılandırılması

ZKA’nın yasal dayanağını oluşturan ve Ağustos 2002 tarihinde yürürlüğe giren Gümrük Soruşturma Hizmetleri Kanunu (Law on the Customs Investigation Service) ile Gümrük Soruşturma Ofisleri doğrudan Zollkriminalant’a bağlanmış ve böylece ZKA yerel ofisleri olan Merkezi bir örgüt haline dönüştürülmüştür. Bahse konu yasa ile, hiyerarşik düzen içinde birleşik bir organizasyon kurulmuş ve ayrıca, gümrük soruşturma ofisleri tarafından elde edilen bilgilerin ZKA tarafından suçların analizinde kullanılması imkanı verilmiştir.

Halen, Köln’de yerleşik bulunan ve Federal Maliye Bakanlığı çatısı altında faaliyet yürüten ZKA, kendisine doğrudan bağlı olan ve Hamburg, Hannover, Berlin, Essen, Dresden, Frankfurt, Stuttgart ve Münih’te bulunan toplam 8 Gümrük Soruşturma Ofisi ve bunlara bağlı 24 şube ile görev yapmaktadır.

2002 tarihli Gümrük Soruşturma Hizmetleri Yasası’nın getirdiği başlıca yenilikleri aşağıdaki gibi sıralamamız mümkündür:

• Gümrük Soruşturma Ofislerinin yetkilerini de üzerine alan ZKA’nın kendi görev alanıyla ilgili soruşturma yapma gücü genişletilmiştir.
• Teknik ekipman kullanımının yaygınlaştırılmasıyla birlikte Gümrük Soruşturmacılarının kişisel korunmaları sağlanmıştır.
• ZKA, polis otoritelerine doğrudan veri transfer etmekle yetkilendirilmiştir.
• Suç soruşturmalarında, kanıtların kullanılması hakkındaki yasak, özel yöntemlerle ve suçu önlemek amacıyla elde edilen istihbarat için geçerliliğini yitirmiştir.

3.3. ZKA’nın Görevleri

Gümrük Soruşturma Hizmetlerini yürüten federal bir merkezi örgüt olarak ZKA’nın başlıca görevleri aşağıdaki gibi sıralanabilir:

• Mali ve diğer Kanunlar gereğince, Gümrük Soruşturma Ofisleri ve Gümrük İdaresinin diğer Ofislerini, soruşturma, suçların önlenmesi, idari suçlar konularında desteklemek,

• Kriminal ve bilimsel incelemeler yapmak ve mahkemelere bu konularda uzmanlık raporları sunmak (Örneğin; el yazısı, mühür, belge ve yaş tespiti gibi)
• Gümrük İdaresi tarafından yönetilen veya gümrük İdaresinin dahil olduğu bilgi sistemleri için veri toplamak ve değişimini yapmak,
• Yabancı gümrük örgütleri ve AB yetkilileri ile adli ve idari konularda karşılıklı yardımlaşmalarda yapmak,
• Ticaretin kontrolü amacıyla dış ticaret alanında işbirliği yapmak,
• Dış Ticaret Kanunu ve Savaş Silahlarının Kontrolü anlaşması gereğince, suçların önlenmesi amacıyla posta ve telekomünikasyonun kontrolünü yapmak,
• Yasadışı teknoloji transferi ve tarım sektöründeki gizli sübvansiyonlarla mücadelede işbirliğine gitmek,
• Avrupa gümrük İdarelerinin, kara, hava ve deniz yolu ile yapılan uyuşturucu kaçakçılığı ile mücadelesi için yapılan bilgi değişiminde merkezi birim olarak görev yapmak,
• Uyuşturucu ilaçların yapımında kullanılabilecek nitelikteki maddelerin takibi amacıyla ticaretin kontrolünü yapmak,
• Ortak Mali Soruşturma Grubu (Federal Polis Ofisi/ZKA) nun yardımıyla kara para aklama suçlarını önlemek,
• Federal Maliye Bakanlığı’nın verdiği yetkiyle sınırlı olmak şartıyla, idari ve adli yardım alanında Gümrük Soruşturma Hizmetlerinin merkezi bir örgütü olarak faaliyet göstermek,
• Gümrük Soruşturma Ofislerinin soruşturmalarının yönetim ve koordinasyonunu yapmak,
• Gümrük Soruşturma Memurlarına ileri düzeyde teknik eğitim vermek,

Öte yandan, Zollkriminalamt’ın uluslararası bilgi sistemine entegre olmak için gösterdiği çabalar, Dünya Gümrük Örgütü’nün 1997 yılında ZKA içerisinde, bir bölgesel ofis kurması ile sonuçlanmıştır. RILO (Regional Intelligence Liason Office for Western Europe) olarak adlandırılan bu ofis, kaçakçılıkla mücadelede kullanılmak üzere bölgesel durum haritaları ve raporları geliştirmekte ve proje bazlı analizler yapmaktadır.

Ayrıca, ZKA, Balkan-Bilgi-Sistemi’nin (BALKAN-INFO) Merkez Ofisi olarak da görev yapmaktadır. Dünya Gümrük Örgütü’nün uluslar arası bilgi sistemi olan ve Türkiye’nin de üye olduğu BALKAN-INFO, üye ülkeler arasında uyuşturucu kaçakçılığı ile ilgili bilgi değişimini gerçekleştirmektedir.

Yabancı gümrük idarelerinden ve AB kurumlarından adli ve idari yardım talebinde bulunmak ve onlara yardım sağlamak Zollkriminalamt’nın başlıca görevleri arasına yer almaktadır. Böylece ZKA, uluslararası suçlarla mücadele alanında sürekli, istikrarlı ve hızlı işbirliği ortamını sağlayabilmektedir.

ZKA’nın başlıca görev alanı içerisinde yer alan vergi kaçakçılığı daha ziyade içki ve sigara kaçakçılığı ve vergisiz sigara ithalatı şeklinde kendini göstermektedir. Almanya, sadece sigara kaçakçılığından yıllık ortalama 500 milyon Euro vergi kaybına uğramaktadır.

AB içerisinde sınır kontrollerinin kaldırılması, kaçakçılıkla mücadele için her alanda uluslararası işbirliği ihtiyacını daha da artırmıştır. Bu işbirliği, ABD ve değişik Avrupa Ülkelerinden gelen irtibat görevlileri ile desteklenmiştir. Halen ZKA, Hollanda, Polonya, Türkiye, Afganistan ve EUROPOL’de kendi irtibat görevlileri tarafından temsil edilmektedir. Bu irtibat görevlileri zinciri, sürekli olarak genişlemektedir(Washington, Londra, Madrid, Roma, Prag, Sofya ve Moskova).

Diğer taraftan, kara paranın aklanmasıyla mücadele alanındaki şartın yürürlüğe girmesiyle, ZKA bir diğer önemli görevi üstlenmiştir. Uyuşturucu kaçakçılığı alanında olduğu gibi, ZKA ve Gümrük Soruşturma Ofisleri Federal Polis Kuvvetleri ile ortak soruşturma grupları oluşturmaya başlamışlardır. Bu kapsamda halen, Kiel, Rostock, Hamburg, Berlin, Hannover, Potsdam, Magdeburg, Dusseldorf, Dresden, Erfurt, Wiesbaden, Saarbrücken, Karlsruhe, Stuttgart, Münih, Freiburg’da olmak üzere toplam 17 merkezde Polis/Gümrük Ortak Mali Soruşturma Grubu (GFG) (Common Groups) görev yapmaktadır. Ayrıca, 27 adet Polis/Gümrük Ortak Narkotik Soruşturma Grubu (GER) Gümrük Soruşturma Ofislerine bağlı olarak faaliyet yürütmektedir.

Gümrük soruşturma hizmetleri alanında bir Merkez Ofisi olan ZKA, aynı zamanda bir Gümrük Soruşturmaları Bilgi Sistemini de idare etmektedir. Özellikle narkotik ve sigara kaçakçılığı alanlarında suçluların güç kullanma eğilimlerinin artması, tehlikeli görevler için özel eğitimli memurlardan oluşan grupların oluşturulmasını gerekli kılmıştır. Bu kapsamda teşkil edilen “Merkezi Gümrük Destek Gruplarında” (ZUZ) görevli memurlar, gelişmiş silahlar ve teknik ekipmanlarla donatılmıştır.

3.4. Gümrük Soruşturmacılarının Yetkileri

Gümrük soruşturma servisi, gümrük idaresinin kriminal polisidir. Gümrük soruşturma ofisleri ve bunların memurları polis ile aynı hak ve yükümlülüklere sahiptir. Nihai karar alma yetkileri bulunmayan soruşturma ofisleri, Alman Ceza Kanununa göre gerçekleri ortaya çıkarmak ve delilleri muhafaza etmekle görevlidirler.

Gümrük soruşturma ofisleri ile ana gümrük müdürlükleri arasındaki işbirliği yerel düzeyde koordine edilmektedir. Gümrük ile ilgili bir suç işlendiğinde ilk yakalamayı ana gümrük ofisleri yapmaktadır. Gümrük soruşturma ofisleri, savcı aracılığıyla hakimden, gecikmesinde sakınca bulunan hallerde doğrudan doğruya savcıdan soruşturma emrini alırlar. Gümrük soruşturma ofisleri soruşturmayı tamamladıktan sonra, düzenleyecekleri bir nihai raporla birlikte olayı savcıya ve gerektiğinde ana gümrük ofislerine intikal ettirirler.

Gümrük soruşturma memurları savcı yardımcısıdırlar. Bunlar, Mahkemelerin Kuruluşu Hakkında Kanun gereğince savcının emirlerini yerine getirmek zorundadırlar(GVG, madde 152). Bu nedenle, savcılar, acil gümrük soruşturmaları dışında kalan diğer adi suçlar için de gümrük soruşturma ofislerine emir verebilmektedirler. Bunlar, gümrük mühürlerinin yasadışı açılması veya orijinal belgeler üzerinde tahrifat yapılması gibi özellikle ithalat, ihracat ya da malların transiti ile bağlantılı olarak işlenen suçlardır.

Ayrıca, soruşturma memurları, Alman Ceza Muhakemeleri Kanunu (StPO) uyarınca, vergi, dış ticaret ve piyasa düzenlemeleri ile ilgili bir suç işlendiğinden şüphe duyulması halinde gerekli tedbirleri almak zorundadırlar.

Gümrük soruşturma memurları, gecikmesinde sakınca bulunan hallerde, esas olarak hakimin yetkisinde olan ve temel hak ve özgürlükleri kısıtlayan hususlarda ön tedbir mahiyetinde emirler verebilmektedirler. Bu koşullarda, söz konusu memurlar savcı yardımcısı sıfatıyla yakalama, arama gibi kesin emirler verme yetkisine sahip bulunmaktadırlar.

Alman Gümrük Soruşturma Hizmetleri Kanunu, Genel Vergi Kanunu(AO), Dış Ticaret Kanunu(AWG), Ortak Piyasa Kuruluşlarının Faaliyetleri Hakkında Kanun(MOG) uyarınca soruşturma yapma yetkisine sahip gümrük soruşturma memurları, yaptıkları soruşturmalar sırasında, Alman Ceza Muhakemeleri Kanununda polisin sahip olduğu hak ve yükümlüklerin aynısına sahiptirler.

Her gümrük soruşturma ofisinin bir görev bölgesi bulunmakla birlikte, federal statüde bulunan gümrük soruşturma memurları, bölge sınırlarıyla bağlı kalmaksızın Federal Almanya’nın her yerinde soruşturmalarını yapabilmektedirler.

Normal koşullarda, tüm adli işlemlerde mahkeme emri alınması gerekmektedir. Ancak, gecikmesinde sakınca bulunan hallerde, gümrük soruşturma memurları suç ihbarlarını kabul etmek, delillerin yok olmasını önlemek amacıyla acil tedbirler almak, şüphelilerin izlenmesi ve gözetlenmesi, sanıkların kimlik tespitini yapmak; şüphelilerin evlerini, diğer mülklerini aramak, sanıkları yakalamak amacıyla diğer kişileri araştırmak, delilleri muhafaza etmek, bedeni muayene emri vermek, Almanya’da sabit ikametgahı olmayanlar için teminat alınmasını emretmek, sanıkların araçlarının ve diğer eşyalarının müsadere edilmesi emrini vermekle yetkilidirler. Öte yandan, telefon görüşmelerinin dinlenmesi ancak mahkeme kararı ile mümkün olabilmektedir.

4. SONUÇ

1993 yılında Avrupa Tek Pazarı’nın tesis edilmesiyle iç sınırlarda gümrük kontrolleri ve Schengen Anlaşması ile de yolcuların polis kontrolleri kaldırılmış böylece AB vatandaşları Birlik içerisinde sınırsız olarak seyahat etme özgürlüğüne kavuşmuşlardır. AB’nin genişlemesi ve sınırlarının Doğu Avrupa Ülkelerine açılması ile birlikte uluslararası organize suçlarda da artış olmuştur. Gümrük ve kaçakçılık suç türlerinde meydana gelen değişiklik, başta Alman Gümrük İdaresi olmak üzere gümrük soruşturma hizmetlerinde yeniden yapılanmayı gerekli kılmıştır. Bu kapsamda, 2002 yılında yürürlüğe giren bir Yasa ile Gümrük Soruşturma Ofisleri doğrudan ZKA’ya bağlanmış, bu ofisler tarafından elde edilen bilgilerin Zollkriminalamt tarafından, suçların analizinde kullanılmasına izin verilmiş, ZKA’nın soruşturma yapma gücü artırılmış, gümrük soruşturmacılarının kişisel korunmaları sağlanmış, ZKA’ya polis otoritelerine doğrudan veri transfer etme yetkisi verilmiştir.

Gümrük soruşturma ofisleri tarafından yapılan soruşturmaları koordine eden, yöneten ve destekleyen ve özel durumlarda kendisi de soruşturma yapabilen Gümrük Kriminal Dairesi’nin yeniden yapılandırılmasıyla birlikte, dış ticaretin gözetimi, özellikle uyuşturucu kaçakçılığıyla mücadele, uluslararası adli ve idari yardımlaşma, risk analizi gibi alanlarda daha etkin hale gelinmiştir. Bu çerçevede, Türk Gümrük İdaresi’nin, AB uyum süreci içerisinde yeniden yapılandırmasını gerçekleştirirken, Alman Gümrük İdaresi’nin ve özellikle ZKA’nın da yakından incelenmesi yararlı olabilecektir.

Kaynaklar :

“Narkotics, Smuggling Via the Balkan Route”, Annual Report 2003, BALKAN-Info System.

“Federal Almanya Gümrük İdaresi web sitesi”, http://www.zoll.de/

“Federal Almanya Maliye Bakanlığı web sitesi”, http://www.bundesfinanzministerium.de/

“ZKA, Zollkriminalamt”, http://www.zollkriminalamt.de/gb/index.htm

“Zollfahndungsdienst, Organisation, Functions, Powers”, http://www.zollkriminalamt.de/gb/index.htm

“Zollkriminalamt, Development and Tasks”, http://www.zollkriminalamt.de/gb/index.htm

http://www.gumrukkontrolor.org.tr/Yayinlar/Dergiler/51/4.html

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ALMAN GÜMRÜK İDARESİ VE ZKA” hakkında 1.991 yorum

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