Briefly, three positions concerning corporate liability may be identified. First, there are systems of full corporate criminal liability, such as those in England and the United States. Second, there are systems that recognize only partial corporate criminal liability, for example Denmark, Belgium, and France. Finally, some systems do not permit such liability at all, or permit it only under the guise of administrative offenses. Italy and West Germany afford examples of this restrictive view of corporate liability.

This Article will sketch each of these positions in some detail, beginning, in Part I, with those systems that authorize full liability. Part II discusses systems that presently fall within the second category noting some recent suggestions for broader liability. Part III deals with systems that provide for only administrative liability, outlining the sanctions developed under those systems. In Part IV, I briefly summarize the sanctions directed against individual corporate directors and officers in all of these systems.