Concise criminal responsibility of legal entities by using a comparative approach to French and American laws

Today, legal persons and real persons are studied in the same way different branches of law. There is a controversy regarding the nature of real persons. Generally speaking, two theories of being real and hypothetical legal person have been presented. Regarding the criminal responsibility of legal entities, two conflicting theories have been expressed. The criminal laws of Iran have an individualistic nature and have not recognized the criminal responsibility of legal entities except in rare cases, and among legal entities, only governments and international governmental organizations have international legal personality. To manage these legal entities, there should be managers who have sufficient authorities, and along theses authorities, managers are obliged to perform some acts and leave some other ones, and along with the increase in their authorities, there are several specific responsibilities toward these managers.
This responsibility is not limited to the commercial law and it is available in some other laws. Requirements have been established for the officials of legal entities, and violation of these requirements is a criminal responsibility. The will of a legal entity is expressed by its managers, and it is natural that legal entities, like natural persons, may commit an act or fail an act in the course of their daily activities that incurs loss to others. Therefore, according to the above mentioned statements, we are going to conduct library research to study the current issue and answer the main question that what is the concise criminal responsibility of legal entities by using a comparative approach to French and American laws?