Companies operating in multiple countries need compliance programs that take into account varying national requirements. In Italy, for example, the Supreme Court recently established that in addition to Italian companies, foreign companies are required to implement compliance programs (known as “231 Models”) that meet the standards provided by Italian Decree No. 231/2001 (“Decree”) in order to avoid corporate criminal liability. [1] What are these standards, and can they be reconciled with the understandable need of companies to have harmonized, coherent, and not overly fragmented compliance systems? Without getting into specifics about individual nations, most of the characteristics of an adequate and effective compliance program are established by international best practices. The

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