Mafia Infiltration and 231: The Milan Stadium Case

1. The fact

   According to reports by «Il Sole 24 Ore» and «Corriere della Sera», the Double Curve investigation culminated in September 2024 with the arrest of 19 members of the organized fan groups of Inter and Milan, including Andrea Beretta, Marco Ferdico, and Luca Lucci. The Milan Prosecutor's Office (DDA) investigations hypothesized the existence of a non-belligerence pact between the two curves to control profits from parking, bars, and merchandising. A pivotal event was the murder of Antonio Bellocco, a figure linked to the 'Ndrangheta, which occurred in September 2024 at the hands of Andrea Beretta. Currently, the procedural stage is that of preliminary investigations (October 2024). The clubs F.C. Internazionale and A.C. Milan are not under investigation for conspiracy crimes but have been subject to prevention proceedings aimed at verifying whether the companies indirectly facilitated these dynamics through deficiencies in their 231 organizational models. National newspapers have highlighted intolerable pressure exerted by ultras on executives and members to obtain logistical and economic benefits.

2. 

   The laws at play

   The regulatory framework centers on Legislative Decree 231/2001, which governs the administrative liability of entities. In this context, the capacity of the Organization and Management Model (MOG) to prevent crimes committed for the benefit of the company, including organized crime, is relevant.

   1. Art. 416-bis of the Criminal Code punishes mafia-type association: the mafia method aggravating factor (416-bis.1 c.p.) is charged against the Curva Nord for ties to the 'ndrangheta, while the Curva Sud is charged with simple criminal association (416 c.p.).
   2. Art. 34 of Legislative Decree 159/2011 (Anti-Mafia Code) provides for judicial administration, a prevention measure applicable when a company, despite not being mafia-owned, negligently facilitates individuals under investigation for criminal association.
   3. Art. 629 of the Criminal Code defines the crime of extortion, which occurs when the company gives in to the fans' demands under threat, finding itself on the delicate borderline between victim and facilitator due to lack of oversight.

3. What the case law says

   Legitimacy jurisprudence has clarified that sports clubs have an obligation to adopt specific prevention models for the risk of environmental conditioning by fan groups. The established orientation distinguishes between the company as a victim of extortion, which reports promptly, and the so-called facilitating victim, which through inertia or convenience maintains opaque relationships with individuals linked to crime. Prevention judges have emphasized that the application of judicial administration is not punitive but therapeutic, serving to decontaminate the entity from external infiltrations. Regarding 231 liability, it has been specified that the MOG must include rigorous protocols for ticket sales and the management of outsourced services, as organizational fault manifests precisely where the corporate structure allows third parties to derive illicit profits by exploiting the club's official channels.

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8. What it teaches professionals

   1. The importance of thorough due diligence not only on direct suppliers but also on entities effectively operating within corporate spaces.
   2. The need to map risks of environmental conditioning, including specific protocols in the MOG for managing relationships with aggressive interest groups.
   3. The strategic role of monitoring cash flows from ancillary activities (parking, bars), often underestimated in 231 risk analyses.
   4. The utility of implementing transparent dialogue channels with public security authorities to formalize the state of subjection and prevent charges of negligent facilitation.

References: D.Lgs. 231/2001D.Lgs. 159/2011Art. 416 c.p.Art. 416-bis c.p.Art. 416-bis.1 c.p.Art. 629 c.p.

Editorial oversight: Avv. Federico Papa·ICAMUpdated 2 October 2026Content drafted with AI support and subject to editorial source checks. Despite these controls, inaccuracies may remain: reports and rectification requests are welcome. Report a correction