MOG and AI-related crimes: adapting the 231 model for digital risks

MOG and AI-related crimes: adapting the 231 model for digital risks

On Agenda Digitale, Mariagiusy Portogallo and Carlo Cunto explore the role of the Organizational and Management Model (MOG) under Legislative Decree 231/2001 in light of new offenses related to artificial intelligence (AI).

According to the article, the MOG—designed to prevent administrative liability of entities—becomes even more vital in the context of AI proliferation. Businesses must integrate AI-related crime protocols into the MOG, update sensitive process mapping, risk assessment, and strengthen internal controls.

Portogallo and Cunto point out that this shift requires a proactive revision of internal supervisory structures (OdV) and organizational models to mitigate emerging legal exposures.

Read the full article by the authors on Agenda Digitale:
Full article here