Newsletter

Corporate Compliance Newsletter - October 2026

November 2, 2026

Criminal liability of company managers and executives

The criminal liability of managers and executives does not arise solely from the positions they hold within a company. Determining such liability requires an analysis of their functions and responsibilities, any delegation of duties, their knowledge of the risk, and their actual ability to prevent it from materializing. In this edition of Foco Compliance, we explain the four key aspects that must be assessed and why a clear organizational structure, with well-defined responsibilities and lines of supervision, is essential for effective risk management and corporate compliance.