Compliance Radar

Who was sanctioned, and for what?

Fines, court rulings and incidents from Europe and North America: 756 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.

13cases from 2 jurisdictions
€19.6mTotal of monetary amounts (11 cases with an amount)
€16.5mLargest single case: J.P. Morgan Securities LLC
€217,195Median per case with an amount

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When?

per quarter, by date of decision
Trend
PeriodCasesTotal
Q3 20230—
Q4 20230—
Q1 20241€16.5m
Q2 20240—
Q3 20246€2.85m
Q4 20240—
Q1 20250—
Q2 20250—
Q3 20250—
Q4 20251€23,018
Q1 20260—
Q2 20263€209,905
Q3 20262€8,222

13 cases

16 Jul 2026 Royal Mail Group LtdTribunal: Royal Mail subjected whistleblower to detriment – £6,978 compensation United KingdomRetaliation against whistleblowers €8,222

The Employment Tribunal in Manchester found that the claimant had been subjected to detriment because of a protected disclosure and awarded her the agreed amount of £6,978.20. The claims for disability discrimination and constructive dismissal were dismissed.

What organisations can take from it

Large organisations, too, must ensure that whistleblowers do not suffer disadvantages in their day-to-day work.

Relevance to training and awareness

How managers handle internal reports

Authority / court
Employment Tribunal
Area of law
Whistleblower protection · Retaliation against whistleblowers
Legal basis
Employment Rights Act 1996, s. 47B (Benachteiligung wegen geschützter Offenlegung)
Action
Other
Status of proceedings
unknown
Sector
Transport, logistics and shipping
Employees
10,000 or more
Published
7 Sep 2026

Original amount 6,978.2 GBP, converted at the ECB reference rate of 16 Jul 2026.

Checked against the official source on 25 Sep 2026 · Direct link

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8 Jul 2026 Hutchison Technologies LtdTribunal: Hutchison Technologies dismissed employee after she raised holiday pay concerns United KingdomRetaliation against whistleblowers Other

An employee of the Dundee-based electrical services provider for gyms (around 140 employees) had pointed out that the technicians' holiday pay was being calculated incorrectly; a few days later her home working arrangement was withdrawn, and on 11 June 2025 she was dismissed. The Employment Tribunal upheld her claims for automatically unfair dismissal (s. 103A) and detriment (s. 47B); compensation will be decided separately.

What organisations can take from it

Employers who worsen working conditions shortly after a disclosure must be able to prove a documented reason unrelated to the disclosure.

Relevance to training and awareness

How managers handle internal reports

Authority / court
Employment Tribunal
Area of law
Whistleblower protection · Retaliation against whistleblowers
Legal basis
Employment Rights Act 1996, ss. 43B, 47B, 103A
Action
Other
Status of proceedings
unknown
Sector
Other
Employees
50 to 249
Published
23 Jul 2026

Checked against the official source on 25 Sep 2026 · Direct link

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3 Jun 2026 Sonus Public Relations LtdTribunal: PR agency Sonus must pay £71,052 after subjecting whistleblower to detriment United KingdomRetaliation against whistleblowers €82,264

The PR agency, which did not appear, lost on all claims: detriment on grounds of whistleblowing (£20,000 for injury to feelings), wrongful termination without notice pay (£3,547.60) and constructive unfair dismissal (basic and compensatory award including a 25 % ACAS uplift). A total of £71,051.82 was awarded.

What organisations can take from it

Employers who do not take part in the proceedings risk, in addition to whistleblower compensation, an uplift for failing to follow the ACAS Code of Practice.

Relevance to training and awareness

How managers handle internal reports

Authority / court
Employment Tribunal
Area of law
Whistleblower protection · Retaliation against whistleblowers
Legal basis
Employment Rights Act 1996, s. 47B (Benachteiligung wegen geschützter Offenlegung); konstruktive unfaire Kündigung; wrongful dismissal
Action
Other
Status of proceedings
unknown
Sector
Other
Published
22 Jul 2026

Original amount 71,051.82 GBP, converted at the ECB reference rate of 3 Jun 2026.

Checked against the official source on 25 Sep 2026 · Direct link

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22 May 2026 Foot Locker, Inc.SEC: Foot Locker pays 148,000 US dollars over award waivers in separation agreements USARetaliation against whistleblowers €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.

What organisations can take from it

When cleaning up clauses, all contract templates must be covered – a single forgotten template is enough for a violation.

Relevance to training and awareness

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.

Checked against the official source on 25 Sep 2026 · Direct link

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19 May 2026 Jusan Technologies LtdTribunal: Jusan Technologies and CEO liable for withheld 600,000 US dollars United KingdomRetaliation against whistleblowers Other

In August 2023, an employee had raised concerns about a possible diversion of funds earmarked for charitable purposes for self-enrichment and about breaches of duty by the CEO. The London South Employment Tribunal found that the company and its CEO personally had withheld from him, for that reason, a payment of 600,000 US dollars owed at the end of his contract (s. 47B (1) and (1A)); compensation will be determined separately.

What organisations can take from it

In the United Kingdom, managers are personally liable if they subject whistleblowers to detriment – for example by withholding contractual payments.

Relevance to training and awareness

How managers handle internal reports

Authority / court
Employment Tribunal
Area of law
Whistleblower protection · Retaliation against whistleblowers
Legal basis
Employment Rights Act 1996, ss. 43B, 43C, 43G, 47B(1) und (1A)
Action
Other
Status of proceedings
unknown
Liability of senior managers
The CEO (referred to in the judgment as the ‘controlling mind’) is personally liable under s. 47B(1A) ERA 1996 (Employment Rights Act 1996).
Published
10 Jul 2026

Checked against the official source on 25 Sep 2026 · Direct link

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22 Oct 2025 Gate GourmetTribunal: Gate Gourmet files no response – £20,000 to whistleblower United KingdomRetaliation against whistleblowers €23,018

Because Gate Gourmet failed to file a response to the claim despite repeated requests, the Manchester Employment Tribunal found that there had been detriment on grounds of a protected disclosure and in January 2026 awarded £15,000 for loss of earnings and £5,000 for injury to feelings. An application for reconsideration, based on an email inbox that was no longer monitored, was refused.

What organisations can take from it

Correspondence from authorities and courts must go to monitored addresses – missed deadlines turn a defensible claim into a default judgment.

Relevance to training and awareness

Managing deadlines and incoming mail in litigation

Authority / court
Employment Tribunal
Area of law
Whistleblower protection · Retaliation against whistleblowers
Legal basis
Employment Rights Act 1996, s. 47B (Benachteiligung wegen geschützter Offenlegung); Employment Tribunal Procedure Rules 2024, Rule 22
Action
Other
Status of proceedings
unknown
Sector
Food and agriculture
Published
7 Jan 2026

Original amount 20,000 GBP, converted at the ECB reference rate of 22 Oct 2025.

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 USARetaliation against whistleblowers €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.

What organisations can take from it

Companies concluding a settlement with a whistleblower may require neither the withdrawal of nor a waiver of reports to authorities.

Relevance to training and awareness

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.

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 USARetaliation against whistleblowers €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.

What organisations can take from it

Separation and employment agreements must restrict neither reports to authorities nor the entitlement to whistleblower awards.

Relevance to training and awareness

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.

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 USARetaliation against whistleblowers €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.

What organisations can take from it

Separation and employment agreements must restrict neither reports to authorities nor the entitlement to whistleblower awards.

Relevance to training and awareness

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.

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 USARetaliation against whistleblowers €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.

What organisations can take from it

Separation and employment agreements must restrict neither reports to authorities nor the entitlement to whistleblower awards.

Relevance to training and awareness

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.

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 USARetaliation against whistleblowers €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.

What organisations can take from it

Separation and employment agreements must restrict neither reports to authorities nor the entitlement to whistleblower awards.

Relevance to training and awareness

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.

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 USARetaliation against whistleblowers €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).

What organisations can take from it

Complaint settlements with clients must not require an assurance not to contact authorities.

Relevance to training and awareness

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 USARetaliation against whistleblowers €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.

What organisations can take from it

Confidentiality clauses with clients must not exclude voluntary reporting to supervisory authorities either.

Relevance to training and awareness

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.

Checked against the official source on 25 Sep 2026 · Direct link

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