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The authors have conducted a brief comparative study of the most striking differences between substantive and procedural aspects of bringing legal entities to responsibility. Taking into account the specifics of the prevailing source (Islamic Shariah) and legal doctrine there is vague distinction between criminal and administrative liability in Arab countries, although legislature (tashri'atun) of the Kingdom of Saudi Arabia provides situations similar to the domestic approach. The authors have highlighted the legal and technical peculiarities of imposition of punishment and their types. As to procedural issues, the legal framework of the United Arab Emirates is characterized more progressive. Despite the fact that both states traditionally belonged to the religious legal family, today the presence of secular law and its content indicates the mixed nature of legal systems.
Volevodz et al. (2024) studied this question.