Кривична одговорност правних лица у англо – америчком праву

The article discusses the institute of corporate criminal liability in common law countries. The author analyses English, American, Canadian and Australian model of corporate criminal liability, including brief historical overview. The first part of the paper focuses on analyzing legal solutions concerning the way criminal liability is attributed to the corporation and the system of criminal sanctions against the corporation. Then, the authors makes arguments about advantages and disadvantages of different models, and concludes the joint analysis of Anglo – American legal systems by emphasizing the trend of introducing solutions which leads to adopting of subjective autonomous liability of corporations.