Area · Businesses and professionals
Compliance & 231 models
Reduce business risk with clear internal rules: organisational models, anti-money-laundering procedures, policies. Documentary work that integrates with privacy compliance.
What we do
Internal rules that hold
231 organisational models
Risk analysis and preparation of the organisational model (Legislative Decree 231/2001): procedures, delegations and safeguards tailored to the business.
Anti-money-laundering (AML)
AML obligations and procedures for obliged entities: customer due diligence, record-keeping, risk assessment.
Policies and codes of conduct
Codes of ethics, tool-use policies, internal regulations: documents consistent with one another and with the GDPR.
Whistleblowing
Reporting channels and procedures compliant with the law, with attention to protecting whistleblowers’ data.
Our work is strictly out-of-court advisory: models, procedures and documents. We don’t take on defence in proceedings or representation in court; for those we refer you to qualified professionals.
- Your group has — or is opening — an Italian subsidiary and you keep hearing about “Decree 231”, under which the company itself can be sanctioned for crimes committed in its interest by directors or staff: you want to know whether and how it affects you.
- A major Italian client, or a public tender, asks for a 231 organisational model as a de facto condition for doing business together, and you don't know where to start.
- Your Italian workforce has reached an average of 50 employees: Legislative Decree 24/2023 now requires an internal whistleblowing channel — with a proper procedure, a designated handler and compliant privacy notices, not just an inbox.
- You operate in a sector subject to Italian anti-money-laundering obligations and want customer due diligence, record-keeping and risk assessment in order before an inspection, not after.
- You have received a supplier-qualification questionnaire from a large Italian customer, full of questions on 231, anti-corruption and whistleblowing, and you're unsure what you can declare without exposing the company.
A written system of rules built to measure, not a photocopied template: risk mapping and the 231 organisational model with its procedures, a complete whistleblowing procedure with privacy notices, an anti-money-laundering manual where applicable, and codes and policies ready for formal adoption by the board or the owner. For foreign groups, everything is aligned with your existing group programme — because an FCPA- or UK Bribery Act-style compliance programme, however solid, does not automatically qualify as a 231 model. Each delivery includes the calendar of recurring obligations and updates.
How it works
The path, in three steps
-
Mapping obligations and risks
Before writing anything, we verify which obligations actually apply to your Italian operations — whistleblowing, anti-money-laundering, a voluntary 231 model — based on size, sector and activity, and how they interlock with your group-level compliance. Then we map the at-risk processes with the people who run them daily, not just from the organisation chart.
-
Building the system
We draft the model, procedures and policies calibrated to the company's real size: sustainable safeguards, delegations that match who actually decides, documents consistent with one another, with privacy compliance and with the parent company's policies. Every draft is discussed with you — in English — before the final version.
-
Adoption and maintenance
We support the formal adoption — board resolutions, appointments including the supervisory body (organismo di vigilanza, the independent body that oversees the model), communication to staff — because an unadopted document protects no one. And we set up what follows: training, information flows to the supervisory body, and updates when the law or the business changes.
FAQ
Frequently asked questions
- What is “Decree 231”, in brief?
- Legislative Decree 231/2001 makes companies and other entities directly liable — with fines and debarment measures — for a list of crimes (corruption, fraud, workplace-safety and environmental offences, certain tax crimes and more) committed in their interest or to their advantage by directors, managers or employees. The main defence is having adopted and effectively implemented an organisational model, overseen by a supervisory body: broadly comparable in function to “adequate procedures” under the UK Bribery Act, but with its own Italian requirements.
- Is the 231 model mandatory?
- No: the decree does not impose it. It is, however, the instrument that can exclude the entity's liability if a crime is committed in its interest, and Italian clients and tenders increasingly require it as a de facto condition. The point is calibration: a copy-paste model that is not actually implemented protects no one — courts look at how it works in practice.
- Does Decree 231 apply to foreign companies?
- It can: Italian courts have applied the decree to foreign companies for offences committed in Italy, even without an Italian branch. And the reverse caution matters too — a group compliance programme built for the FCPA or the UK Bribery Act does not automatically satisfy the decree's requirements. If you operate in Italy, the exposure is worth assessing in writing; that assessment is where we usually start.
- How long does it take, and what does it cost?
- For an SME or an Italian subsidiary, a 231 model typically takes some weeks between interviews, risk mapping and drafting, plus the time for formal adoption; a standalone whistleblowing procedure takes less. Timing and fee are set out in writing before we start, after a first picture of the business — no engagement begins without an agreed scope, and the work runs remotely, in English.
- If an inspection or proceeding starts, can you defend us?
- No — our work is strictly out-of-court advisory. What we build and document is the compliance system itself, which is exactly what gets examined in those settings; but we do not act as defence counsel in proceedings. If that becomes necessary, we refer you to qualified Italian lawyers and hand over an ordered documentary corpus that saves precious time.
Insights
Related insights
Contact
A model to build, procedures to put in place?
Tell us about the business and the obligations that apply to you: we’ll propose a clear path.
First reply within one business day. The first contact is free and carries no obligation.