A Comparative Study of Provisions on Criminal Liability of Legal Entities in the Criminal Law of Algeria, Morocco and Vietnam

Abstract

This article presents a new research on a number of issues  concerning  corporate  criminal  liability  from  comparative  law  perspective  in  the criminal law of Algeria, Morocco and Vietnam, such as: History; legal persons are the subject of offences and the subject of criminal liability; scope of corporate criminal offences; elements of corporate criminal law; principles of attributing criminal liability to juridical persons, types of penalties and judicial/security measures applied to juridical persons committing crimes.  On the premise of comparative law research, the article draws some conclusions and proposes recommendations to improve the provisions on corporate criminal liabililty in the current Penal Code of Vietnam.

Keywords: Criminal liability of legal entities, comparison of Criminal Laws of Algeria, Morocco, Vietnam, penalties for legal entities committing crimes.