Comparing Corp. Criminal Liability In US, UK, France: Part 1
By Mark Srere, Andrew Tuson, Oran Gelb, Constantin Achillas and David PereApril 23, 2018, 3:55 PM EDT
Law360 (April 23, 2018, 3:55 PM EDT) -- Shakespeare’s observation that the “past is prologue” certainly applies to corporate criminal liability in the United Kingdom and France, as these jurisdictions embrace with gusto corporate prosecutions akin to those pursued in the United States for decades. This article, the first in a series about corporate compliance from Bryan Cave Leighton Paisner LLP’s global investigations team, considers the current position on corporate criminal liability in the U.S., U.K. and France.
U.S.: A Long-Established Doctrine
In the U.S., the principle underlying corporate criminal liability is respondeat superior....