Compliance Radar
Who was sanctioned, and for what?
Fines, court rulings and incidents from Europe and North America: 718 cases from 32 jurisdictions, each with an official source and checked against that source before publication. Filter by country, area of law and sector. Click a chart to drill down one level.
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Where?
by authority- U.S. Securities and Exchange Commission €19.5m 100 % · 8 cases
What for?
by topicWho?
by sectorAll sectors
When?
per quarter, by date of decision| Period | Cases | Total |
|---|---|---|
| Q3 2023 | 0 | — |
| Q4 2023 | 0 | — |
| Q1 2024 | 1 | €16.5m |
| Q2 2024 | 0 | — |
| Q3 2024 | 6 | €2.85m |
| Q4 2024 | 0 | — |
| Q1 2025 | 0 | — |
| Q2 2025 | 0 | — |
| Q3 2025 | 0 | — |
| Q4 2025 | 0 | — |
| Q1 2026 | 0 | — |
| Q2 2026 | 1 | €127,641 |
| Q3 2026 | 0 | — |
8 cases
22 May 2026 Foot Locker, Inc.SEC: Foot Locker pays 148,000 US dollars over award waivers in separation agreements €127,641
From July 2020 to June 2024, around 148 departing employees – including managers and staff from finance, legal and supply chain – signed separation agreements containing a waiver of SEC whistleblower awards. Foot Locker had itself phased out the clause from March 2024 but had not amended all templates; the U.S. Securities and Exchange Commission (SEC) imposed 148,000 US dollars.
When cleaning up clauses, all contract templates must be covered – a single forgotten template is enough for a violation.
Whistleblower protection in contract templates (HR/Legal)
- Authority / court
- U.S. Securities and Exchange Commission
- Area of law
- Whistleblower protection · Retaliation against whistleblowers
- Legal basis
- Securities Exchange Act of 1934, Rule 21F-17(a)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Retail and e-commerce
- Employees
- 10,000 or more
- Mitigating circumstances
- Clause phased out before contact by the SEC; cooperation and prompt remediation
- Published
- 22 May 2026
Original amount 148,000 USD, converted at the ECB reference rate of 22 May 2026.
- In the Matter of Foot Locker, Inc., Release No. 34-105542 Decision of an authority
- SEC Whistleblower Protections – Enforcement Actions Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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26 Sep 2024 GQG Partners LLCSEC: GQG Partners pays 500,000 US dollars over NDAs and severance agreement €448,229
The asset manager had twelve job applicants sign NDAs that prohibited voluntary reports to authorities, and, in a settlement agreement, required a former employee who had announced a report to the SEC to confirm that he had not initiated any investigation and to withdraw statements already made. The U.S. Securities and Exchange Commission (SEC) took cooperation and remediation into account and imposed 500,000 US dollars.
Companies concluding a settlement with a whistleblower may require neither the withdrawal of nor a waiver of reports to authorities.
Handling announced reports to authorities in separation negotiations
- Authority / court
- U.S. Securities and Exchange Commission
- Area of law
- Whistleblower protection · Retaliation against whistleblowers
- Legal basis
- Securities Exchange Act of 1934, Rule 21F-17(a); Investment Advisers Act Section 203(e)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Financial services and insurance
- Employees
- 50 to 249
- Mitigating circumstances
- Cooperation with the SEC and prompt remedial measures
- Published
- 26 Sep 2024
Original amount 500,000 USD, converted at the ECB reference rate of 26 Sep 2024.
- In the Matter of GQG Partners LLC, Release No. 34-101200 Decision of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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9 Sep 2024 Acadia Healthcare Company, Inc.SEC: Acadia Healthcare pays 1,386,000 US dollars over waivers of whistleblower awards €1.26m
Between July 2019 and July 2023, Acadia Healthcare had employees waive potential awards for reports to authorities in 98 employment, separation, retention and settlement agreements; in 56 further separation and settlement agreements, they had to waive complaints to federal authorities. As part of a sweep against seven listed companies, Acadia paid 1,386,000 US dollars to the U.S. Securities and Exchange Commission (SEC); the contract templates were amended.
Separation and employment agreements must restrict neither reports to authorities nor the entitlement to whistleblower awards.
Whistleblower protection in contract templates (HR/Legal)
- Authority / court
- U.S. Securities and Exchange Commission
- Area of law
- Whistleblower protection · Retaliation against whistleblowers
- Legal basis
- Securities Exchange Act of 1934, Rule 21F-17(a)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Healthcare
- Mitigating circumstances
- Partial amendment of the templates even before contact by the SEC, information provided to those affected, and cooperation
- Published
- 9 Sep 2024
Original amount 1,386,000 USD, converted at the ECB reference rate of 9 Sep 2024.
- SEC Charges Seven Public Companies with Violations of Whistleblower Protection Rule Press release of an authority
- In the Matter of Acadia Healthcare Company, Inc., Release No. 34-100970 Decision of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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9 Sep 2024 AppFolio, Inc.SEC: AppFolio pays 692,250 US dollars over waivers of whistleblower awards €626,868
The provider of property management software had employees waive potential awards for reports to authorities in two employment agreements and one settlement agreement; 68 consulting agreements (January 2020 to October 2023) prohibited voluntary disclosures to authorities. As part of a sweep against seven listed companies, AppFolio paid 692,250 US dollars to the U.S. Securities and Exchange Commission (SEC); the contract templates were amended.
Separation and employment agreements must restrict neither reports to authorities nor the entitlement to whistleblower awards.
Whistleblower protection in contract templates (HR/Legal)
- Authority / court
- U.S. Securities and Exchange Commission
- Area of law
- Whistleblower protection · Retaliation against whistleblowers
- Legal basis
- Securities Exchange Act of 1934, Rule 21F-17(a)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Telecoms, IT and software
- Mitigating circumstances
- Amendment of the templates after contact by the SEC, information provided to those affected, and cooperation
- Published
- 9 Sep 2024
Original amount 692,250 USD, converted at the ECB reference rate of 9 Sep 2024.
- SEC Charges Seven Public Companies with Violations of Whistleblower Protection Rule Press release of an authority
- In the Matter of AppFolio, Inc., Release No. 34-100971 Decision of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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9 Sep 2024 TransUnionSEC: TransUnion pays 312,000 US dollars over waivers of whistleblower awards €282,532
Between May 2019 and September 2023, TransUnion had senior employees waive potential awards for reports to authorities in 29 severance, separation and incentive agreements; three consulting agreements prohibited voluntary disclosures to authorities. As part of a sweep against seven listed companies, TransUnion paid 312,000 US dollars to the U.S. Securities and Exchange Commission (SEC); the contract templates were amended.
Separation and employment agreements must restrict neither reports to authorities nor the entitlement to whistleblower awards.
Whistleblower protection in contract templates (HR/Legal)
- Authority / court
- U.S. Securities and Exchange Commission
- Area of law
- Whistleblower protection · Retaliation against whistleblowers
- Legal basis
- Securities Exchange Act of 1934, Rule 21F-17(a)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Financial services and insurance
- Mitigating circumstances
- Amendment of the templates after contact by the SEC, information provided to those affected, and cooperation
- Published
- 9 Sep 2024
Original amount 312,000 USD, converted at the ECB reference rate of 9 Sep 2024.
- SEC Charges Seven Public Companies with Violations of Whistleblower Protection Rule Press release of an authority
- In the Matter of TransUnion, Release No. 34-100975 Decision of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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9 Sep 2024 Smart for Life, Inc.SEC: Smart for Life pays 19,500 US dollars over waivers of whistleblower awards €17,658
The manufacturer of nutrition and wellness products had two departing employees waive potential awards for reports to authorities in separation agreements (May 2022 and June 2023). As part of a sweep against seven listed companies, Smart for Life paid 19,500 US dollars; the U.S. Securities and Exchange Commission (SEC) also took into account the company's strained financial situation.
Separation and employment agreements must restrict neither reports to authorities nor the entitlement to whistleblower awards.
Whistleblower protection in contract templates (HR/Legal)
- Authority / court
- U.S. Securities and Exchange Commission
- Area of law
- Whistleblower protection · Retaliation against whistleblowers
- Legal basis
- Securities Exchange Act of 1934, Rule 21F-17(a)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Food and agriculture
- Mitigating circumstances
- Amendment of the templates and information provided to those affected after contact by the SEC, cooperation and strained financial situation
- Published
- 9 Sep 2024
Original amount 19,500 USD, converted at the ECB reference rate of 9 Sep 2024.
- SEC Charges Seven Public Companies with Violations of Whistleblower Protection Rule Press release of an authority
- In the Matter of Smart for Life, Inc., Release No. 34-100974 Decision of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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4 Sep 2024 Nationwide Planning Associates, Inc.; NPA Asset Management, LLC; Blue Point Strategic Wealth Management, LLCSEC: Nationwide Planning and partners pay 240,000 US dollars over reporting prohibitions €217,195
From May 2021 to February 2024, the three New Jersey firms had eleven retail clients sign confidentiality agreements in connection with settlement payments that permitted reports to the SEC only at the SEC's initiative; in some cases, clients had to confirm that they had never contacted and would never contact authorities. Penalties imposed by the U.S. Securities and Exchange Commission (SEC): 160,000 (NPA Asset Management), 70,000 (Nationwide Planning) and 10,000 US dollars (Blue Point).
Complaint settlements with clients must not require an assurance not to contact authorities.
Whistleblower protection in complaint and settlement processes
- Authority / court
- U.S. Securities and Exchange Commission
- Area of law
- Whistleblower protection · Retaliation against whistleblowers
- Legal basis
- Securities Exchange Act of 1934, Rule 21F-17(a)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Financial services and insurance
- Published
- 4 Sep 2024
Original amount 240,000 USD, converted at the ECB reference rate of 4 Sep 2024.
Checked against the official source on 25 Sep 2026 · Direct link
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16 Jan 2024 J.P. Morgan Securities LLCSEC: J.P. Morgan Securities pays 18 million US dollars over gagging clauses in client settlements €16.5m
From March 2020 to July 2023, JPMS had hundreds of retail clients who received credits or settlement payments of more than 1,000 US dollars sign confidentiality agreements that permitted responses to SEC enquiries but prohibited voluntary contact with the SEC. The U.S. Securities and Exchange Commission (SEC) imposed 18 million US dollars.
Confidentiality clauses with clients must not exclude voluntary reporting to supervisory authorities either.
Whistleblower protection in settlement and confidentiality agreements
- Authority / court
- U.S. Securities and Exchange Commission
- Area of law
- Whistleblower protection · Retaliation against whistleblowers
- Legal basis
- Securities Exchange Act of 1934, Rule 21F-17(a)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Financial services and insurance
- Employees
- 10,000 or more
- Published
- 16 Jan 2024
Original amount 18,000,000 USD, converted at the ECB reference rate of 16 Jan 2024.
- J.P. Morgan to Pay $18 Million for Violating Whistleblower Protection Rule Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link