Final Remarks: Criminal Liability and Compliance Programs

Abstract

In our introductory chapter we identified a worldwide trend towards a “due diligence” model of corporate liability: corporations are now, not only held liable for the misdeeds of their most senior corporate officers; offenses committed by more junior employees or agents may also be imputed to them – if those offenses were the expression of high-level mismanagement. We observed this development in the conditions and defenses to CCL, as well as in national corporate prosecution and sanctioning guidelines.