The EPPO and Corporate Enforcement—Known Unknowns

4 December 2019
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Key takeaways:
  • The EPPO will have jurisdiction to pursue companies for offences affecting the European Union’s financial interests, although important aspects relevant to the scope of corporate liability will require clarification.
  • Companies held liable in proceedings handled by the EPPO will be sentenced according to the sentencing regime applicable in the Member State where the case is brought.
  • Key areas relevant to the EPPO regime for corporate actors that will likely require further clarification are the EPPO’s approach to co-operating companies as well as how it will manage differences among Member States in the procedural status of the corporate victim and the availability of non-conviction resolutions.