Can DAOs be prosecuted for facilitating money laundering or other financial crimes?

Select jurisdiction

  • Italy


Considering that money laundering, as well as some
financial crimes (e.g., market abuse) are listed in the
Legislative Decree no. 231/2001 (the “Decree”) as
predicate offenses, if (a) DAO may be incorporated as one
of the entities to which the Decree applies, and (b) the
offenses are committed by DAO’s associates in its interest
or to its benefit and it has not adopted and effectively
implemented compliance programs suitable to prevent
the commission of such offenses, then the DAO could be
held responsible for the sole ground of commission of
such offenses.

Lydia Mendola

IP lawyer

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