<p>Global value chains have transformed corporate activity into a transnational enterprise, while systems of criminal liability remain largely confined within national boundaries. This article examines the resulting accountability gap through the lens of corporate criminal liability, focusing on how existing doctrines respond to harm arising from fragmented production networks. Rather than advancing new regulatory models, the article undertakes a doctrinal and comparative analysis of how different legal systems conceptualise corporate fault, attribution and responsibility in transnational contexts. It argues that the core challenge lies not in the absence of liability mechanisms, but in their misalignment with the organisational realities of global value chains. By comparing selected jurisdictions, the article identifies both converging tendencies and persistent divergences in approaches to corporate knowledge, control and delegation. It contends that meaningful transnational accountability requires a recalibration of existing doctrines, rather than their replacement, grounded in a clearer understanding of corporate structures and decision-making processes. The article contributes to ongoing debates on corporate accountability by highlighting both the limits and the potential of doctrinal alignment in an increasingly interconnected economic order.</p>

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Corporate Criminal Liability in Global Value Chains: Transnational Responsibility and Doctrinal Alignment

  • Thao Le Thi

摘要

Global value chains have transformed corporate activity into a transnational enterprise, while systems of criminal liability remain largely confined within national boundaries. This article examines the resulting accountability gap through the lens of corporate criminal liability, focusing on how existing doctrines respond to harm arising from fragmented production networks. Rather than advancing new regulatory models, the article undertakes a doctrinal and comparative analysis of how different legal systems conceptualise corporate fault, attribution and responsibility in transnational contexts. It argues that the core challenge lies not in the absence of liability mechanisms, but in their misalignment with the organisational realities of global value chains. By comparing selected jurisdictions, the article identifies both converging tendencies and persistent divergences in approaches to corporate knowledge, control and delegation. It contends that meaningful transnational accountability requires a recalibration of existing doctrines, rather than their replacement, grounded in a clearer understanding of corporate structures and decision-making processes. The article contributes to ongoing debates on corporate accountability by highlighting both the limits and the potential of doctrinal alignment in an increasingly interconnected economic order.