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.

2cases from 1 jurisdiction
€127.5mTotal of monetary amounts
€63.7mMedian per case with an amount

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When?

per quarter, by date of decision
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Q1 20252€127.5m
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2 cases

16 Jan 2025 Two Sigma Investments LP und Two Sigma Advisers LPTwo Sigma: 90 million USD – known weaknesses in investment models left unremedied for years USAOrganisational requirements €87.6m

Employees identified weaknesses in investment models that could affect client returns by March 2019 at the latest, but Two Sigma only acted in August 2023; there were no policies, and one employee made unauthorised changes to more than a dozen models. In addition, separation agreements required employees to declare that they had not filed any complaint with authorities. The U.S. Securities and Exchange Commission (SEC) imposed 90 million USD; Two Sigma had already repaid 165 million USD to clients.

What organisations can take from it

Model risks need a change and approval procedure – and identified weaknesses need a binding deadline for remediation.

Authority / court
U.S. Securities and Exchange Commission (SEC)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Investment Advisers Act of 1940 (Antifraud, Compliance Rule 206(4)-7); Exchange Act Rule 21F-17(a)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Culpability
intentional
Mitigating circumstances
Voluntary repayment of 165 million USD to affected funds and accounts.

Original amount 90,000,000 USD, converted at the ECB reference rate of 16 Jan 2025.

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

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13 Jan 2025 BMO Capital Markets Corp.BMO Capital Markets: 40.7 million USD – inadequate supervision of bond desk USAOrganisational requirements €39.9m

From December 2020 to May 2023, staff on the agency CMO bond desk sold mortgage-backed bonds worth around 3 billion USD using misleading metrics; the broker-dealer’s supervisory procedures contained no requirements for the structuring and sale of these bonds. BMO paid 19,417,908 USD in disgorgement, 2,241,507 USD in interest and a civil penalty of 19 million USD.

What organisations can take from it

Tailor supervisory procedures to the actual products and sales practices of each desk – generic policies are not enough.

Authority / court
U.S. Securities and Exchange Commission (SEC)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Securities Exchange Act of 1934, Section 15(b)(4)(E) (Failure to supervise)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more

Original amount 40,659,415 USD, converted at the ECB reference rate of 13 Jan 2025.

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

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