Criminal compliance


Criminal compliance is a comprehensive set of procedures and standards of behavior applicable in a business environment. The purpose of criminal compliance is to ensure that a company’s operations comply with criminal laws and to minimize criminal risks when conducting business.

Irregularities that may occur within the activities of business entities may result in individual liability of persons who, working within the organization, commit criminal acts under the Criminal Code, the Fiscal Criminal Code, the Tax Ordinance and other special laws. An important aspect that business entities should pay special attention to is the possibility of holding the entire enterprise criminally liable. In Polish regulations, this issue is regulated in the Liability of Collective Entities Act.

Fines and other punitive measures can be imposed on the company, in the form of, for example, a ban on promotion or advertising, a ban on bidding for public contracts or making the verdict public. The liability of companies depends on actions related to the prevention of economic crime relating to their business, and therefore, among other things, on the criminal compliance policy implemented. This involves both criminal and financial liability. That is why it is so important to take all possible preventive measures that will exempt companies from potential criminal liability.

The potential consequences of committing a criminal act by a business entity also have an image dimension. As long-time practitioners in the area of criminal law for business, we effectively identify criminal risks and, as part of the criminal compliance service provided by KKZ, we comprehensively create and implement solutions to protect the image, good name and assets of our clients.

Our offer includes:

  • assessment of criminal legal risks in the organization;
  • conducting a criminal compliance audit within the entity;
  • development of appropriate internal procedures and regulations in the field of criminal compliance, adapted to Polish legal regulations, such as anti-corruption policy, procedure for verification of contractors (KYC), procedure for keeping records and internal reporting, and support in their implementation;
  • support in the creation of corporate documents specifying the area of responsibility of authorities, other organizational units, employees, persons authorized to act on behalf of or in the interest of the entrepreneur;
  • support in the creation of a procedure for dealing with inspections by law enforcement agencies;
  • consulting in the design and implementation of control mechanisms to protect the interests of the company;
  • consulting in the area of whistleblower protection and in eliminating cases of fraud and strengthening internal controls;
  • providing training in the area of criminal compliance;
  • conducting internal investigations aimed at identifying potential criminal legal risks or detecting irregularities that expose the organization or its bodies to liability or damage;
  • coordinating activities to support the management of corporate image crisis through cooperation with PR experts.

The above services are directed to:

  • owners and managers of companies;
  • auditors and supervisors of companies’ activities;
  • entities exposed to liability related to economic crimes;
  • whistleblowers;
  • in-house legal departments seeking criminal compliance support.

How can
we help you?

the experts

Maciej Zaborowski

Advocate, Managing Partner

Paweł Gołębiewski

Attorney-at-law, Head of International Criminal Law Practice