From EU Legislative Texts to Member States’ Legal Conceptual Systems: Bridging the Gap between Italian and British Criminal Law

Cooperation in the fields of justice and home affairs within the EU leads to the drafting of a number of legal instruments and documents referring to a unique sui generis supranational legal system which directly affects the Member States’ legal systems by being implemented and expressed in all the official languages of the EU following the ‘equal authenticity’ principle. The terminological analysis of the Council Framework Decision 2001/220/JHA on the standing of victims in criminal proceedings and other relevant documents enabled us to identify the differences in the Italian and British implementation strategies and in their way of conceptualising key issues, such as the concepts of ‘victim’ and ‘victim support organisation’, proving the existence of more than one conceptual system and different degrees of terminological/translational equivalence and consequently pointing out a terminological and cultural gap which necessarily needs to be taken into account in cross-cultural legal communication.