Decree 231 of 2001 does not include specific provisions regarding foreign companies. However, a general principle of Italian criminal law¹ establishes that all offenses committed in Italy can be punished under Italian law, even if they are committed by a foreign natural person or a foreign company. Offenses are considered to have been committed in Italy when the act or omission representing the offense takes place in Italy, or when the offense produces a harmful effect in Italy.

Pursuant to this general principle, criminal courts have ruled that foreign companies may be held liable under Decree 231 when their directors, managers, employees or agents commit an offense contemplated by Decree 231 in the territory of Italy or, if the consequences of the crime were suffered in Italy, abroad.