N.Y. Laws » CHAPTER Penal / PART General Provisions / TITLE Principles of Criminal Liability / ARTICLE Parties to Offenses and Liability Through Accessorial Conduct
New York Consolidated Laws

N.Y. Penal Law § 20.25 (2026)

Criminal liability of an individual for corporate conduct

✓ current as of May 2026
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§ 20.25 Criminal liability of an individual for corporate conduct.
  A person is criminally liable for conduct constituting an offense
which he performs or causes to be performed in the name of or in behalf
of a corporation to the same extent as if such conduct were performed in
his own name or behalf.
Notes of Decisions
Cited in 16 cases, 1987–2017 · leading case: People v. Concert Connection, Ltd., 211 A.D.2d 310 (N.Y. App. Div. 1995).
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People v. Concert Connection, Ltd., 211 A.D.2d 310 (N.Y. App. Div. 1995). · cites it 2× “To hold otherwise would be an open invitation to individuals to form shell corporations for the purpose of shielding themselves from liability for illegal business transactions (see also, People v Sakow, 45 NY2d 131, 135-136 ; Penal Law §20.25; Donnino, Practice Commentary,…”
People v. First Meridian Plan. Corp., 201 A.D.2d 145 (N.Y. App. Div. 1994). · cites it 2× “Last in this regard, the fact that property was obtained by corporations in which Kagin had an interest, as well as by corporations in which Berman had an interest, rather than by the individuals themselves, does not preclude a finding of criminal liability against Kagin and…”
People v. Byrne, 570 N.E.2d 1066 (NY 1991). “Indeed, holding this defendant liable merely because of his status as a corporate officer and shareholder would run counter to Penal Law § 20.25, which limits individual liability for corporate criminal acts to cases where the individual defendant personally "perform[ed] or…”
Lewis v. Welch, 126 A.D.2d 519 (N.Y. App. Div. 1987). “However, the employees’ criminal culpability which may be imputed to the corporation by the statute cannot be further imputed to its individual directors, whose culpability requires their "knowledge or privity” in the prohibited act (see, People v Brainard, 192 App Div 816, 819…”
People v. Premier House, Inc., 174 Misc. 2d 163 (N.Y. City Crim. Ct. 1997). “(See, United States v Dotterweich, 320 US 277 [1943]; People v Byrne, 77 NY2d 460 [1991]; see also, Penal Law §§ 20.25, 20.05.) "Whether or not these individual defendants can be deemed to be "in control” of the subject premises in their capacities as officers of the Board, and…”
People v. Durch, 140 Misc. 2d 353 (N.Y. City Crim. Ct. 1988). “) *357 Thus, defendant’s motion for dismissal of the informations and underlying violations on the basis that he has "no individual involvement” with the Premises (or that he cannot personally be held criminally liable in these circumstances) is denied. The court now turns to…”
Kuriansky v. Azam, 151 Misc. 2d 176 (N.Y. Sup. Ct. 1991). · cites it 4× “10 or does the court create its own criteria since Judiciary Law §§ 750 to 752 do not specify any standard? What is the standard for holding an individual liable for the acts of a corporation? Does the court apply the civil rule regarding liability of an individual for the…”
People v. Claudia Dowling, Inc., 57 Misc. 3d 52 (N.Y. App. Term. 2017). · cites it 2× “With respect to Claudia Dowling’s contention that the evidence presented at trial failed to demonstrate that she had any personal liability, we note that, pursuant to Penal Law § 20.25, “[a] person is criminally liable for conduct constituting an offense which he [or she]…”
People v. Williams, 144 Misc. 2d 688 (N.Y. Sup. Ct. 1989). “Penal Law §20.25 (1), for example, provides in pertinent part: "The presence of a controlled substance in an automobile * * * is presumptive evidence of knowing possession thereof by each and every person in the automobile at the time such controlled substance was found”.”
People v. Roth, 176 A.D.2d 1186 (N.Y. App. Div. 1991). “The individual defendants may be held criminally liable for corporate conduct constituting such offenses (see, Penal Law § 20.25) and each individual defendant was actively involved in the operation of the corporate facility.”
People ex rel. Allen v. Dooley, 156 A.D.2d 406 (N.Y. App. Div. 1989). “As such the petitioner may be held criminally responsible for the acts of the corporation under the provisions of Penal Law § 20.25 (see, People v Dean, 48 AD2d 223 ; cf, People v Caruso, 135 AD2d 550 ).”
People v. Knox, 25 Misc. 3d 34 (N.Y. App. Term. 2009). “Penal Law § 20.25; People v Sakow, 45 NY2d 131 [1978]).”
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