CRIMINAL LIABILITY OF LEGAL ENTITIES IN ANGLO-AMERICAN LAW

Abstract

The article discusses the institute of corporate criminal liability in common law countries. The author analyses English, American, Canadian and Australian model of corporate criminal liability, including brief historical overview. The first part of the paper focuses on analizying legal solutions concerning the way criminal liability is attributed to the corporation and the system of criminal sanctions againtz the corporation. Then, the authors makes arguments about advantages and disadvenatges of different models, and concludes the joint analysis of Anglo – American legal systems by emphasising the trend of introducing solutions which leads to adopting of subjective autonomous liability of corporations.