Chapter

Comparative and international solutions

Celia Wells

in Corporations and Criminal Responsibility

Second edition

Published in print May 2001 | ISBN: 9780198267935
Published online March 2012 | e-ISBN: 9780191683411 | DOI: http://dx.doi.org/10.1093/acprof:oso/9780198267935.003.0007

Series: Oxford Monographs on Criminal Law and Justice

Comparative and international solutions

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This chapter presents the developments in corporate liability in other common law jurisdictions, in the civil law states of Europe. It also provides an introduction to international and supra national efforts to combat corporate crime through harmonized responses. It is specifically divided into four sections: comparative cautions; common law variations; civil law changes; and convergence. The legal principles in the common law jurisdictions of England and Wales, the United States, Australia, Canada, and New Zealand are shown. In general, the range of solutions to the problem of holding corporations criminally liable in common law, civil law, and international jurisdictions are explained.

Keywords: corporate liability; international jurisdictions; civil law; corporate crime; England; Wales; United States; Australia; Canada; New Zealand

Chapter.  9333 words. 

Subjects: Public International Law

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