Die strafrechtliche Verantwortung der juristischen Person: Rechtsvergleichende Überlegungen zwischen Finnland und Estland
Keywords:corporate criminal responsibility, comparative criminal law, Finland, Estonia
Applying a comparative perspective, the paper examines questions related to corporate criminal responsibility in Finland and Estonia. Corporate criminal liability was introduced in 1995 in Finland and in 2001 in Estonia, via regulations implemented in conjunction with comprehensive reform to the penal codes of these countries. Both the legislation and the legal practices of the two manifest many similarities, partly in principle and partly de facto. However, differences can be noticed – i.a., in the ways in which allocation of the individual’s criminal liability for organisational crime is regulated, alongside how the maximum sentences and the determination of punishments are regulated.