For any company, the risk that employees or agents may engage in criminal conduct in connection with their work and thereby potentially expose the company (or at least the responsible individuals) to criminal

The Italian Supreme Court, in a decision of April 2020, upheld significant prior lower court decisions. It held that foreign companies can be liable for the “administrative” (quasi-criminal) liability governed by Legis­­lative Decree No. 231 of June 8, 2001 (“Decree No. 231/01″) for crimes committed in their interest, or for their benefit, in Italy by their senior managers or employees.