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ARTICLE · 29 JANUARY 2026

Ensure Compliance Programs Keep Up With New Corporate Criminal Offenses

A&O Shearman
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The goal of recent law reforms in many jurisdictions is to make it easier to hold businesses to account for offenses committed by their directors, employees, agents and other associated parties, a corporate criminal liability risk that has been developing over several years.

United StatesCriminal Law

The goal of recent law reforms in many jurisdictions is to make it easier to hold businesses to account for offenses committed by their directors, employees, agents and other associated parties, a corporate criminal liability risk that has been developing over several years.

This means that any analysis of corporate exposure following allegations of misconduct should factor in the jurisdictions involved, and the risk of corporate (and individual) liability. Businesses should reduce their financial crime risk and maximize their chance of successfully mounting a "reasonable procedures" defense, where applicable, by implementing an effective compliance program.

New laws specifically aimed at making it easier to prosecute businesses

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