Introduction

The manner in which organized crime is carried out is different from many other crimes.
Most thefts and assaults do not entail planning or organization in their commission. They
are most commonly the result of spontaneous decisions made by individuals as the
opportunity presents itself. Sometimes these criminal decisions are irrational and carried
out for emotional or symbolic reasons.

Organized crime, by definition, requires more than one person and some degree of
planning and organization in carrying out the criminal conduct. Even though the crime
itself could be committed by an individual (e.g., illicit drug sales), organized crime
requires more people and planning to carry out this crime on a systematic basis.
Therefore, the more systematic nature of organized crime activity makes it more serious
with the potential of causing greater harm and affecting more victims over a longer
period of time.

Several criminal offences have been established over the years to capture the organized
commission of crimes due to their greater seriousness and the need to make distinctions
between, for example, an individual drug seller and the trafficking of narcotics of a
systematic scale. Similarly, there is a large difference between one individual exploiting
another versus the operation of a human trafficking enterprise. This Module examines
offences that involve organizing the commission of crimes.

Topics covered

● Criminalizing participation in an organized criminal group

● Conspiracy
● Criminal association
● Membership in an organized criminal group
● Racketeer Influenced and Corrupt Organizations (RICO)
● Obstruction of justice
1 | Page
Learning outcomes

● Understand the elements of conspiracy and criminal association as legal tools in

proving organized criminal conduct.
● Recognize the concept of racketeering as a method to criminalize those who
organize to commit crime as part of an ongoing enterprise.
● Apply the elements of obstruction of justice in protecting organized crime activity. 

Key Issues

This section provides a descriptive overview of the key issues that lecturers might want
to cover with their students when teaching on this topic. 

● Legal definitions of organized crimes

● Conspiracy
● Criminal association
● Definitions in the Organized Crime Convention
● Criminal organizations and enterprise laws
● Enabling offence: obstruction of justice
● Summary
● References 

 Legal definitions of organized crimes

Organized crime is often defined in sweeping terms. Comments such as "mob-linked"

activity, crimes that bear the "earmarks of the mafia," and other suggestive terms do not
help differentiate organized crimes from conventional crimes in an objective way. This
Module is designed to provide clarity in classifying organized crimes and in
distinguishing them from traditional crimes.
The Organized Crime Convention in its article 5 offers States parties two alternative
options to criminalize participation in an organized criminal group: conspiracy and
criminal association. These offences create criminal liability for persons who intentionally

2 | Page
participate in or contribute to the criminal activities of organized criminal groups. They
are aimed at tackling organized crime at its core by criminalizing acts that involve
participation in or contributions to an organized criminal group. The offences are
designed to be preventive, by creating liability distinct from the attempt or completion of
the criminal activity. They hold criminally liable those who associate for criminal
endeavours, even if they have not yet committed an offence. They can extend criminal
liability to situations in which crime is anticipated and likely to occur, but a specific
offence has yet to materialize. They apply to groups of persons acting in concert to
commit (serious) crime (e.g., provision of illicit goods or services, or infiltration of
business or government).
In simple terms, conspiracy is an offence that is based on an agreement to commit
crime, whereas criminal association is an offence for participating in the activities of an
organized criminal group. Conspiracy is used in common law countries, such as Canada,
Myanmar, Pakistan, Uganda and the US, and criminal association is the principle used in
civil law countries, such as Algeria, France, Gabon, Germany, Italy, Romania, Spain,
Turkey, and Venezuela. Several countries, such as the UK, have elements of both
models concurrently. 

Conspiracy

Conspiracy occurs when two or more persons agree to commit a crime-an essential
feature for committing organized crime. One purpose of the conspiracy offence is to
extend liability "backwards" by criminalizing the planning (or agreement) stage of a
criminal offence. Conspiracy can create criminal liability even if no preparation of the
contemplated offence has begun. In many jurisdictions, an act in furtherance of the
agreement is required. The offence thus serves to prevent crime and allows criminal
justice agencies to intervene (and enables charges to be laid) some time before an
offence is actually attempted or completed. The criminalization of conspiracy has a
further purpose in that it allows for prosecution of multiple persons involved in a criminal
enterprise. The offence attaches liability to agreements to commit crime, which enables

3 | Page
the prosecution of persons who organize and plan crime but do not themselves execute
those plans. It is defined as an inchoate crime, or an act engaged in toward the
commission of a criminal act.
The agreement must be made between at least two persons; an agreement with oneself
is not possible. Jurisprudence suggests that, while the agreement cannot exist without
communication between the conspirators, there is no requirement that the parties to the
agreement know each other. All that is required is that each conspirator is committed to
the agreed objective(s). There is no requirement regarding the level of involvement of a
conspirator in the agreement. The agreement may envisage that all conspirators equally
take some action towards the agreed goal, but a conspirator may also be part of the
agreement without carrying out any action aimed at achieving the common objective.

Purpose of the conspiracy

agreement
The Organized Crime
Convention makes an
important addition to the
general common-law concept
of conspiracy by requiring that
the purpose of the agreement
between the conspirators is to
obtain a financial or other
material benefit. This element
is reflective of the overall
objective of the Convention
and one of the main
characteristics of organized
crime, which is to achieve a
financial or other material
gain from criminal activity.

The most important elements of the crime of conspiracy are the act ( actus reus) and the
state of mind (mens rea) required. They are summarized in Table 2.1. It is important to
note that there are differences among countries in how conspiracy is defined, but the
significant elements of the crime are summarized here.

Table 2.1 Elements of conspiracy in the Organized Crime Convention

4 | Page
 Organized
Physical elements Mental elements
Crime
(actus reus) (mens rea)
Convention

The agreement was entered into

Agreeing with one or
intentionally. The agreement was made
Article 5, para. more other persons to
for a purpose related directly or indirectly
1(a)(i) commit a serious
to obtaining a financial or other material
crime (action)
benefit

Source: United Nations Office on Drugs and Crime. (2012). Model Legislative Provisions
against Organized Crime. Vienna: UNODC.

To summarize, according to the Organized Crime Convention, liability for conspiracy

generally requires a voluntary agreement between two or more people, the parties do
not have to be involved extensively with the conspiracy, and the object is to commit a
serious crime. An overt act in furtherance of the conspiracy is required in many
jurisdictions.

Criminal association

While conspiracy is the main legal tool for addressing criminal enterprises in common
law countries, most civil law countries prefer the legal concept of punishing participation
in a criminal association (or organization or group). This is called the offence of criminal
association - i.e., association de malfaiteurs, since the model of such criminal provisions
are Articles 265-268 of the Criminal Code of France of 1810 (Calderoni, 2010).
Participation of the accused in a criminal organization is the offence, rather than an
agreement between members of the organization or planning a crime with others, which
is the focus of conspiracy. For both conspiracy and criminal association, the participation
in the group, or planning of the crime, is a separate offence from any ultimate crimes that
are carried out.

5 | Page
 Intention to take part in the
criminal group and
knowledge of the aim
Like conspiracy, there is
variation among nations in
the scope of their criminal
association laws, although in
every case the participation
in the criminal group is the
central element, rather than a
specific agreement to
commit a crime. The
elements of the offence of
criminal association require
that the accused had
intention to take part in the
criminal group or its
activities with knowledge of
at least the group's general
aims.

If the participation relates to other, non-criminal activities of the organized criminal group,
the accused must have known that such participation will contribute to achieving the
criminal aim. This may include persons who commit a criminal offence in pursuit of the
aims of, or on behalf of, the organized criminal group, but also persons who operate
legitimate front operations in support of an organized criminal group or who provide
services, such as bookkeeping, knowing that such conduct contributes to the
achievement of the criminal aims of the group. Therefore, association with a group that
has a criminal objective results in criminal responsibility. Table 2.2 summarizes important
elements of criminal association, although some differences exist among national laws.

Table 2.2 Elements of criminal association in the Organized Crime Convention

6 | Page
 Organized
Physical elements Mental elements
Crime
(actus reus) (mens rea)
Convention

Through an act or omission, The act or omission is intentional

Article 5, para. take an active part in and undertaken with knowledge of
1(a)(ii)a criminal activities of the the criminal nature of the group, or
organized criminal group of its criminal activities or objectives

Through an act or omission, The act or omission is intentional

Article 5, para. take an active part in other and undertaken with knowledge that
1(a)(ii)b (non-criminal) activities of participation will contribute to the
the organized criminal group achievement of the criminal aim

Source: United Nations Office on Drugs and Crime. (2012). Model Legislative Provisions
against Organized Crime. Vienna: UNODC.

The offences for participation in a criminal association in civil law jurisdictions perform an
analogous function of the conspiracy offences in common law jurisdictions. In recent
years, some countries of both legal traditions have introduced both conspiracy and
criminal association laws as a method to deal with organized criminal groups, as
analysed in more detail in the following section of this Module. Many have restricted their
use to certain kinds of serious offences (Calderoni, 2012; Hauck and Peterke, 2016;
Sergi, 2014).

Definitions in the Organized Crime Convention

The Organized Crime Convention aims at meeting the need for a global response and at
ensuring the effective criminalization of acts of participation in criminal groups. Article 5
of the Convention recognizes the two main approaches to such criminalization that are
cited above as equivalent. The two alternative options of article 5, paragraph 1 (a) (i) and

7 | Page
paragraph 1 (a) (ii) were thus created to reflect the fact that some countries have
conspiracy laws, while others have criminal association laws. The Convention requires
States parties to criminalize at least one such offence as distinct from the attempted or
completed criminal activity. 

Recognizing the legal differences among Member States, States parties to the
Convention are permitted to use either the conspiracy approach, or the criminal
association approach, as a legal method to punish participation in criminal organizations,
or participation in the offences of criminal enterprises.

The two criminal offences considered thus far - conspiracy and criminal association -
perform an analogous function in jurisdictions with different legal traditions. Nonetheless,
they are inherently different. As detailed in previous sections of this Module, conspiracy
is a crime that creates criminal responsibility for the mere fact of agreeing to commit a
criminal offence, irrespective of whether the objective is carried out or even attempted
(Okoth, 2014). It is distinct and separate from the substantive crime that the conspirators
plan to commit. Therefore, in principle, a defendant may be convicted for both
conspiracy and its underlying crime. On the contrary, the crime of participation in a
criminal association (or organization, or group) in many jurisdictions merges into the
substantive offence once the underlying crime is carried out.

Criminal organizations and enterprise laws

In order to tackle organized crime and, in particular, its infiltration and exertion of corrupt
influence over legitimate businesses, the United States introduced the offence of
racketeering. Racketeering is a newer kind of law with a similar objective to conspiracy
and criminal association, but with a broader scope. The offence of racketeering is not
included in the Organized Crime Convention. It provides for extended penalties for
crimes committed as part of an ongoing criminal enterprise. It is sometimes referred to
as RICO for the Racketeer Influenced and Corrupt Organizations (RICO) Act, a United

8 | Page
States federal law passed in 1970, and makes it unlawful to acquire, operate, or receive
income from an enterprise through a pattern of racketeering activity.
Although only a limited number of Member States have a legislation similar to RICO,
several countries have laws with similar intent, but the scope of these laws varies
considerably. Australia, Canada, Italy, New Zealand and South Africa are examples with
newer laws aimed at racketeering activity such as financial crime, bank transactions,
corruption, cybercrime, and other forms of transnational crime. A significant number of
racketeering cases involve international organized crime, using the Internet and
international exchanges to provide illicit goods and services (Ayling and Broadhurst,
2014; Heber, 2009; Salvador, 2015; Sergi, 2014).

Definition of a racketeering
enterprise
An enterprise under RICO is
defined as any legal or
illegal ongoing business or
group that is used as a base
for criminal activity.
Racketeering activity can be
defined broadly, and many
felonies suffice for liability,
if conducted as part of an
enterprise and pattern. An
enterprise can be any
individual or group (legal or
illegal organization) that
commits these crimes. The
pattern is two or more
felonies committed within a
10-year period (excluding
any periods of imprisonment
of the defendants).

9 | Page
The RICO law attaches extended penalties (up to 20 years of imprisonment) for crimes
committed in "racketeering" fashion, that is, specified felonies committed as part of a
criminal enterprise and as part of a pattern. These RICO provisions were established to
attack organized criminal groups and their operations.
The precise scope and meaning of "enterprise," "pattern," and the activities that suffice
for "racketeering activity" have been developed through a series of domestic court
decisions and interpretations, as is customary in the common law tradition, and
racketeering cases now include corporate misconduct, public corruption, and other
ongoing criminal activity. It is the enterprise that lies at the centre of racketeering
(Kleemans, 2017; State of New Jersey Commission of Investigation, 2011; Transcrime,
2012; U.S. Department of Justice, 2016).
Figure 2.1 illustrates the differences in the three approaches to the criminalization of
organized crime. Conspiracy focuses on the planning of criminal acts, criminal
association focuses on membership in criminal groups, whereas racketeering focuses on
ongoing criminal enterprises.

Figure 2.1: Approaches to organized crime: conspiracy, criminal association,

racketeering

10 | Page
Racketeering is a tool for the criminal justice system to go after those criminal
enterprises that engage in ongoing organized crime activity, rather than only prosecute
individuals or groups for specific illegal acts. It was observed more than 80 years ago
that "racketeering cannot exist without protection" (Chamberlin, 1932). Criminalization of
racketeering aims to remove some of the protection that surrounds criminal enterprises
by exposing those involved to extended penalties beyond those entailed by the crimes
themselves.
In addition to the offences of conspiracy, criminal association and racketeering, liability
needs to be extended to persons who provide advice or assistance in the commission of
serious crimes involving organized crime. This liability specifically includes persons
intentionally organizing, directing, aiding, abetting, facilitating or counselling the
commission of serious crime involving an organized criminal group, as the Organized
Crime Convention states. These provisions enable the prosecution of leaders,
accomplices, organizers, and arrangers, as well as lower-level participants, in the
commission of serious crimes. Aiding, abetting, facilitating or counselling also covers
secondary parties and accomplices who are not themselves principal offenders.

11 | Page
Enabling offence: obstruction of justice
Another characteristic of organized crime is its ongoing nature. Organized criminal
groups form and continue in order to exploit criminal opportunities on a systematic basis,
so there is a need to organize the illicit activity, plan and monitor its execution, and
protect the criminal enterprise from discovery by authorities. One way in which criminal
enterprises attempt to protect themselves is through obstruction of justice. It is all too
common for members of organized criminal groups to eliminate witnesses, use physical
force against police investigators and threaten judges and prosecutors. Indeed, many
people have lost their lives or faced serious attacks in their quest to bring organized
criminal groups and their associates to justice. 

The Organized Crime Convention, in article 23, requires the criminalization of obstruction
of justice. Obstruction of justice combines the protection of the life and safety of the
person with the protection of the integrity of the criminal justice system, and those
participating and working within it. Under the Convention, obstruction of justice includes
the use of inducements, force, threats or intimidation to interfere with witnesses and
judicial or law enforcement officials whose role is to produce accurate evidence and
testimony.

One of the two obstruction of justice offences in the Organized Crime Convention relates
to efforts to influence potential witnesses and others in a position to provide the
authorities with relevant evidence. The obligation for States parties is to criminalize both
the use of corrupt means (such as bribery) and of coercive means (such as threats or
violence). This conduct may be employed against any person, private individuals or
public officials who participate in proceedings involving a Convention offence.

The other obstruction of justice offence in the Organized Crime Convention relates to
conduct intended to pervert the course of justice by use of coercive means, i.e., physical
force, threats or intimidation against law enforcement and judicial officials. The conduct

12 | Page
is aimed at law enforcement and judicial officials. In addition, the Convention requires
the criminalization of corruption.

It is not necessary to succeed in the attempt to obstruct justice, as long as the defendant
carries out the required act with the necessary intent. In other words, it suffices to show
that the accused person acted with the intention to induce false testimony or to interfere
in the giving of testimony or the production of evidence; it is not necessary to prove that,
because of his or her conduct, false testimony or evidence was actually induced or
provided. It is also not required to show that the exercise of the official's duties was
actually interfered with; any intention to do so fulfils the elements of the offence. For
example, in one case, the defendant made a conditional threat that if he was forced to
meet with the tax authorities, he would bring a gun and "someone might be shot" (U.S. v.
Price, 1991). The court in this case held that this threatening act (although never actually
carried out) constituted obstruction of justice. The mens rea (guilty mind) requirement
involves specific intent to interfere with the administration of justice.  

Article 23 of the Organized Crime Convention requires States parties to prohibit

obstruction of justice, involving force, threats or promises to interfere in the investigative
and judicial process. These requirements are also included as article 25 in the UN
Convention against Corruption (UNODC, 2004):

(a)  The use of physical force, threats or intimidation or the promise, offering or giving of
an undue advantage to induce false testimony or to interfere in the giving of testimony or
the production of evidence in a proceeding in relation to the commission of offences
covered by this Convention;

(b)  The use of physical force, threats or intimidation to interfere with the exercise of
official duties by a justice or law enforcement official in relation to the commission of

13 | Page
offences covered by this Convention. Nothing in this subparagraph shall prejudice the
right of States parties to have legislation that protects other categories of public officials.

The Organized Crime Convention places States parties under an obligation to

criminalize conduct that involves obstructing justice in the trial phase, and also in the
pre-trial phase, which could include obstructing an investigation.

14 | Page
 Variations in obstruction of
justice laws
A review of the scope and
application of the obstruction
of justice offences under
domestic laws reveals a
significant variation among
countries in the types of
conduct and the types of
persons/victims covered. The
tendency among countries
has been not to have an
overarching offence
encompassing all forms of
obstruction of justice, but to
cover all the forms through a
combination of multiple,
overlapping provisions
(UNODC, 2015).

In some countries, the

offences also extend to
selected persons outside
government systems, for
example journalists who may
be threatened or harmed in
the course of their
journalistic investigations
and revelations. Similarly,
domestic laws may cover
persons related, connected or
known to the official or to
the person participating in
the criminal justice process,
in addition to direct
participants.

15 | Page
The focus of the Organized Crime Convention on obstruction of justice targets the
person who incites, induces or causes another person to give false testimony or provide
false evidence, not on the person who gives false evidence. In other words, obstruction
of justice is closely linked to but does not equal perjury - which involves giving false
testimony in court, especially when under oath. Similarly, a distinction is made between
"the promise, offering or giving of an undue advantage" as corrupt means in obstruction
of justice as well as other general offences relating to corruption and bribery. Obstruction
of justice also links to witness protection (UNODC, 2012; UNODC, 2015).

16 | Page
Summary
"Conspiracy" and "criminal association" are characteristic organized crimes offences in
that they criminalize the planning of crimes by groups and associating with organized
criminal groups. Organized crime requires more than one person, and some rational
planning and organization to carry out the criminal conduct successfully.

"Racketeering" is a newer approach to punishing ongoing criminal enterprises.

Obstruction of justice is an example of a crime used by organized criminal groups to
ensure their survival from law enforcement and prosecution as well as to continue to
profit illegally. 
 

References

● Ayling, Julie and Roderic Broadhurst (2014). Organized Crime Control in

Australia and New Zealand. In L. Paoli, ed. The Oxford Handbook of Organized
Crime. Oxford University Press.
● Calderoni, Francesco (2010). Organized Crime Legislation in the European
Union: Harmonization and Approximation of Criminal Law, National Legislations
and the EU Framework Decision on the Fight against Organized Crime . Springer
Science & Business Media.
● Calderoni, Francesco (2012). "U.N. Convention against Transnational Organized
Crime." In Encyclopedia of Transnational Crime and Justice , edited by Margaret
E. Beare. Thousand Oaks, CA: Sage Publications, Inc.
● Chamberlin, Henry Barrett (1932). Some Observations Concerning Organized
Crime. Journal of Criminal Law and Criminology, vol. 22, 667.
● Hauck, Pierre and Sven Peterke, eds. (2016). International Law and
Transnational Organised Crime. Oxford University Press.
● Heber, Anita (2009). Networks of Organised Black Market Labour in the Building
Trade. Trends in Organized Crime, vol. 12, 122-144.

17 | Page
 ● Kleemans, E.R. (2017). 'Organized Crime and Places.' In G.J.N. Bruinsma and
S.D. Johnson, eds. Oxford Handbook of Environmental Criminology . Oxford:
Oxford University Press.
● New York State Organized Crime Task Force. (1990). Corruption and
Racketeering in the New York City Construction Industry . New York University
Press.
● Okoth, J.R.A. (2014). The Crime of Conspiracy in International Criminal Law .
Springer.
● Salvador, W. Joseph (2015). Dismantling the Internet Mafia: RICO's Applicability
to Cyber Crime. Rutgers Computer & Technology Law Journal , vol. 41, 268-297.
● Sergi, Anna (2014). Organised Crime in Criminal Law: Conspiracy and
Membership Offences in Italian, English and International Frameworks. King's
Law Journal, vol. 25, 185-200.
● State of New Jersey Commission of Investigation (2011). Industrious Subversion:
Circumvention of Oversight in Solid Waste andRecycling in New Jersey .
Commission of Investigation.
● Transcrime (2012). Study on Extortion and Racketeering: The Need for an
Instrument to Combat Activities.  Bruxelles : Commission européenne.
● United Nations Office on Drugs and Crime (2004). United Nations Convention
against Transnational Organized Crime and the Protocols Thereto . Vienna:
UNODC. 
● United Nations Office on Drugs and Crime (2004). United Nations Convention
against Corruption. Vienna: UNODC.
● United Nations Office on Drugs and Crime (2012). Model Legislative Provisions
against Organized Crime. Vienna: UNODC.
● United Nations Office on Drugs and Crime (2015). Legislative Guide for the
Implementation of the United Nations Convention against Transnational
Organized Crime and the Protocols Thereto. Vienna: UNODC.

18 | Page
 ● U.S. v. Herrera (2016). WL 561904, United States District Court, N.D. Illinois,
Eastern Division. No. 14 C 1933.
● U.S. Department of Justice (2016). Criminal RICO: 18 U.S.C. §§1961-1968, A
Manual for Federal Prosecutors. Washington DC: U.S. Department of Justice.
● Weber, T. (2001). Thirty-Five Tagged in Formula Drug Scheme. Associated
Press, December 14.

Exercises

● Case studies
o Drug Smuggling Conspiracy
o United States v. John Cody
● Thinking critically through fiction: Blood Diamond
● Excerpts of legislation
o An example of the enterprise model: United States of America
o An example of the common law offence of conspiracy: Ireland, Criminal
Justice Act 2006
o An example of criminalizing the participation in a criminal organization:
Italy, Penal Code

Core reading

Legal

Article in United Nations Convention Against Transnational Organized Crime and the
Protocols Thereto

● Article 5: Criminalization

19 | Page
Legislative Guides for the Implementation of the United Nations Convention against
Transnational Organized Crime and the Protocols Thereto

● Criminalization of participation in a criminal group

Academic Literature

● Boister, N. (2016). Chapter 7 "The UN Convention Against Transnational

Organized Crime 2000" (pp. 126-149) in P. Hauck and S. Peterke
(eds.), International Law and Transnational Organised Crime. New York, NY:
Oxford University Press. 
● Sergi, Anna (2014). Organised Crime in Criminal Law: Conspiracy and
Membership Offences in Italian, English and International Frameworks. King's
Law Journal, vol. 25, 185-200.

Reports

● Library Briefing (2013). The EU Response to Organised Crime. Library of the

European Parliament.  

Advanced reading

● Calderoni, Francesco (2010). Organized Crime Legislation in the European

Union: Harmonization and Approximation of Criminal Law, National Legislations
and the EU Framework Decision on the Fight against Organized Crime . Springer
Science & Business Media.
● Okoth, J.R.A. (2014). The Crime of Conspiracy in International Criminal Law .
Springer.
● Salvador, W. Joseph (2015). Dismantling the Internet Mafia: RICO's Applicability
to Cyber Crime. Rutgers Computer & Technology Law Journal , vol. 41, 268-297.

Research and independent study questions

20 | Page
a)  Given the different legal traditions of Member States of the European Union, there
initially was very little agreement related to combating organized crime. In the EU, there
are three approaches to criminalizing organized crime: a) civil law approach that consists
of criminalizing participation in a criminal association; b) common law approach based
on conspiracy, i.e., an agreement to commit a crime, and c) the so-called Scandinavian
approach that rejects "criminal organization" offences and relies instead on the general
provisions of criminal law (e.g. complicity, aiding and abetting). The EU's 2008
Framework Decision, which sought to find a compromise between diverse legal
traditions, has been criticized. How have the EU's policies evolved in the context of
criminalizing organized crime? What is the current legal basis for establishing minimum
standards for the definition of criminal offences and sanctions in the areas of serious
crime, particularly with a cross-border dimension?

b)  On 21 November 1980, Genovese crime family boss Frank "Funzi" Tieri was the first
mafia boss to be convicted under the RICO Act. Discuss the significance of this case for
the development of a legal response against organized criminal groups in the United
States and other countries.

c)  Compare the excerpts of legislation provided in the Module (for the United States,
Ireland, and Italy) and review additional national legislation available from SHERLOC
Database of Legislation, such as relevant legislation in your country. Identify the
differences and similarities between these legal texts and discuss whether they follow
any of the models of criminalization of participation in an organized criminal group
discussed in the Module.

21 | Page