Human rights abuses and gross crimes can be supported by a wide range of legally permitted professional activities. Originating in German criminal law, the term “neutral acts” emphasizes such activities’ normal appearance, linking it to an alleged normative neutrality ruling out responsibility for complicity. At the descriptive level, the unsuspicious appearance of these acts is emphasized, filtered out from morally and legally culpable consequences and presented as the essential feature, which is also intended to mark the limits of the actor's responsibility. To what extent business-related contributions to crime should enjoy immunity from accountability is a relevant issue for domestic and international law, as well as soft law aiming at preventing corporate complicity in human rights violations.

This paper critically engages with arguments in favor of business acts’ liability neutralization, focusing on three types: first, weighing up interests, second, alleged lack of subjective liability and third, alleged lack of objective liability. Inquiring strategies of neutralization can help define a normative framework for complicity through allegedly neutral actions, ruling out apparently sound arguments and exposing their undue implications.