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.

29cases from 15 jurisdictions
€163.8mTotal of monetary amounts (27 cases with an amount)
€362,000Median per case with an amount

Click a bar to drill down one level.

When?

per quarter, by date of decision
Trend
PeriodCasesTotal
Q3 20230—
Q4 20230—
Q1 20241€2.2m
Q2 20240—
Q3 20240—
Q4 20244€26.3m
Q1 20253€127.7m
Q2 20250—
Q3 20255€730,000
Q4 20254€191,000
Q1 20263€1.83m
Q2 20267€4.53m
Q3 20262€364,687

29 cases

16 Sep 2026 AIFM Capital ABAIFM Capital: 2 million SEK for inadequate selection and oversight of fund managers SwedenOrganisational requirements €177,187

As a so-called fund hotel, the company had its funds managed by other firms, but examined these delegation agreements only insufficiently, did not take the related decisions properly and did not monitor the funds’ returns in relation to risk closely enough. The Swedish financial supervisory authority Finansinspektionen (FI) issued a remark and imposed 2 million SEK; no damage to investors was established.

What organisations can take from it

Outsourcing tasks does not outsource responsibility: document the selection of service providers, the decisions taken and ongoing oversight.

Authority / court
Finansinspektionen (FI)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Schwedisches Fondsrecht – Regeln zur Delegation der Fondsverwaltung und deren Überwachung
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
No established damage to investors; remedial measures already taken during the investigation.
Published
16 Sep 2026

Original amount 2,000,000 SEK, converted at the ECB reference rate of 16 Sep 2026.

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

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10 Jul 2026 Brown Capital Management LLCBrown Capital Management: voting rights notifications not submitted on time GermanyDisclosure and reporting obligations €187,500

The Baltimore-based US asset manager had not submitted voting rights notifications to the issuer and BaFin in time; the deadline is four trading days after reaching a notifiable threshold. BaFin imposed a fine of 187,500 EUR; the notice is final.

What organisations can take from it

Anyone investing in German issuers needs automated threshold monitoring with clear responsibility for the four-day deadline.

Relevance to training and awareness

Threshold monitoring and notification deadlines for shareholdings

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
§ 33 Abs. 1 Satz 1 WpHG
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
22 Jul 2026

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

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30 Jun 2026 Moody's Deutschland GmbHESMA fines Moody's Deutschland 2.1 million EUR EU levelOrganisational requirements €2.15m

The credit rating agency did not submit up-to-date rating information to the European Securities and Markets Authority (ESMA), did not provide complete historical performance data to the central repository and lacked adequate procedures and internal control mechanisms. ESMA found negligent infringements and imposed fines totalling 2,145,000 EUR.

What organisations can take from it

Reporting obligations to the supervisory authority are data quality issues – without functioning internal controls, they become a risk of fines.

Authority / court
Europäische Wertpapier- und Marktaufsichtsbehörde (ESMA)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Verordnung (EG) Nr. 1060/2009 (CRA-Verordnung), Art. 24, 36a, Anhang III
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Culpability
negligent
Repeat case
yes

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

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30 Jun 2026 „Paysera LT“, UABPaysera: daily fine for missing annual accounts adds up to 362,000 EUR LithuaniaDisclosure and reporting obligations €362,000

Because Paysera did not comply with the order to submit its 2024 annual financial statements by 30 September 2025, the Lietuvos bankas (Bank of Lithuania, financial supervisor) first imposed 20,000 EUR in November 2025 and then a daily fine of 1,000 EUR (rising to 2,000 and 3,000 EUR respectively). As the infringement was only remedied after 6 May 2026, the daily fine added up to 362,000 EUR. Source: archived copy of the press release.

What organisations can take from it

Running daily fines make every delay expensive – supervisory orders need top-management priority.

Authority / court
Lietuvos bankas (Litauische Zentralbank, Finanzaufsicht)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Aufsichtsrechtliche Anordnung und Berichtspflichten nach litauischem E-Geld-Recht
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Repeat case
yes
Published
30 Jun 2026

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

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26 Jun 2026 Banque Degroof Petercam SABanque Degroof Petercam: 1 million EUR settlement over hidden costs in employee stock options BelgiumOrganisational requirements €1m

In stock option plans for employees of client companies (2018–2023), the bank did not fully inform the beneficiaries about costs, had initially not recorded the conflicts of interest in this business and assessed clients’ knowledge only with a yes/no question. The Autorité des services et marchés financiers (Belgian Financial Services and Markets Authority, FSMA) accepted a settlement of 1 million EUR with publication by name and commitments on cost information.

What organisations can take from it

Full cost transparency and a dedicated conflicts register also apply to ancillary business such as employee stock option plans.

Authority / court
Autorité des services et marchés financiers (FSMA)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Loi du 2 août 2002; Wohlverhaltensregeln (Loyalität, Kostentransparenz, bestmögliche Ausführung, Interessenkonflikte, Kundenkenntnis)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Repeat case
yes
Mitigating circumstances
Remediation of all deficiencies (appropriateness test, conflicts policy, cost disclosure, waiver of CVA/KVA discounts).
Published
26 Jun 2026

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

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25 May 2026 Robomarkets LtdCyprus: Robomarkets pays 100,000 EUR under settlement over CFD sales to retail clients CyprusOrganisational requirements €100,000

For the period June 2023 to June 2024, the Cyprus Securities and Exchange Commission (CySEC) examined the investment firm’s organisational requirements, client information, appropriateness assessment and compliance with the restrictions on marketing CFDs to retail investors. The proceedings were concluded with a settlement of 100,000 EUR, which the company has already paid.

What organisations can take from it

When selling CFDs to retail clients, the appropriateness assessment and product intervention rules are central points of supervisory scrutiny.

Relevance to training and awareness

Appropriateness assessment when selling complex products

Authority / court
Cyprus Securities and Exchange Commission (CySEC)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Art. 22(1), 25(1), 26(3) Gesetz über Wertpapierdienstleistungen 2017; Art. 42 VO (EU) 600/2014; CySEC-Richtlinie DI87-09; Art. 37(4) CySEC-Gesetz
Action
Other
Status of proceedings
final
Sector
Financial services and insurance
Published
24 Aug 2026
Sources

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

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13 May 2026 Oma Säästöpankki OyjOma Säästöpankki: 400,000 EUR over late and incomplete insider lists FinlandMarket abuse and insider dealing €400,000

The bank failed to draw up insider lists in good time for two pieces of inside information (termination of the core banking project with Cognizant in 2021, merger talks with Liedon Säästöpankki in 2022), did not update them and omitted mandatory information. The Finanssivalvonta (Finnish Financial Supervisory Authority, FIN-FSA) imposed a total fine of 400,000 EUR; the decision was not appealed and is final.

What organisations can take from it

Insider lists must be created from the moment inside information exists – a fixed process with designated responsible persons prevents gaps.

Relevance to training and awareness

Insider lists and handling of inside information

Authority / court
Finanssivalvonta (FIN-FSA)
Area of law
Capital markets and financial supervision · Market abuse and insider dealing
Legal basis
Verordnung (EU) Nr. 596/2014 (MAR) Art. 18 Abs. 1, 3 und 4; Durchführungsverordnung (EU) 2016/347
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Measures to prevent recurrence and partial admission/cooperation had a mitigating effect.
Published
15 May 2026

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

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5 May 2026 P&V Assurances SCP&V Assurances: 150,000 EUR – distribution via a deregistered insurance intermediary BelgiumOrganisational requirements €150,000

One of the insurer’s intermediaries was removed from the FSMA register in December 2023; owing to a human data entry error in the monitoring tool, P&V only noticed this after more than a month and concluded 34 contracts through him during that time. The Autorité des services et marchés financiers (Belgian Financial Services and Markets Authority, FSMA) accepted a settlement of 150,000 EUR; there had already been a settlement for the same amount in 2020.

What organisations can take from it

Automated register checks are only as good as the underlying data maintenance – critical entries require a four-eyes principle.

Relevance to training and awareness

Care in master data maintenance / register reconciliation

Authority / court
Autorité des services et marchés financiers (FSMA)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Loi du 4 avril 2014 relative aux assurances, Art. 259
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Repeat case
yes
Mitigating circumstances
IT adjustments to prevent recurrence.
Published
5 May 2026

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

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15 Apr 2026 Liquidnet Canada Inc.Liquidnet Canada: confidential order data passed on to unauthorised persons Canada, ONOrganisational requirements €369,572

The operator of alternative trading systems passed on confidential order and trading information from its fixed income and equity platforms to unauthorised employees, lacked adequate safeguards and was initially not forthcoming with the regulator. Sanctions: administrative penalty of 600,000 CAD, 75,000 CAD in costs, a reprimand and an external review.

What organisations can take from it

Technically restrict access rights to confidential client data and review them regularly – and make complete reports to the regulator.

Relevance to training and awareness

Need-to-know principle and protection of confidential trading data

Authority / court
Capital Markets Tribunal (Ontario) auf Antrag der Ontario Securities Commission
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
National Instrument 21-101, s. 5.10(1)-(3); Securities Act (Ontario) ss. 127(1), 127.1
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Cooperation, self-report, no prior record

Original amount 600,000 CAD, converted at the ECB reference rate of 15 Apr 2026.

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

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27 Mar 2026 Dinosaur Merchant Bank LimitedDinosaur Merchant Bank: 338,000 GBP – CFD trading without market abuse surveillance United KingdomOrganisational requirements €389,760

After a new order management system was introduced in June 2024, CFD transactions with an underlying value of around 3.05 billion USD were not captured by automated trade surveillance. The bank identified the error in October 2024 but only remedied it in May 2025; the Financial Conduct Authority (FCA) imposed 338,000 GBP after a 30% cooperation discount.

What organisations can take from it

With every system migration, check whether surveillance systems actually capture the new data flows.

Authority / court
Financial Conduct Authority (FCA)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Art. 16 Abs. 2 UK MAR; SYSC 6.1.1R; FCA Principle 3
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Full cooperation (30% discount); CFD business discontinued in May 2025.

Original amount 338,000 GBP, converted at the ECB reference rate of 27 Mar 2026.

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

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25 Mar 2026 Familiam Asset Management OyFamiliam Asset Management: 70,000 EUR for 2,867 unreported securities transactions FinlandDisclosure and reporting obligations €70,000

Between September 2021 and August 2023, the asset manager failed to report a total of 2,867 transactions to the supervisory authority on time and in 2024 also submitted quarterly reports (FINREP) late. The Finanssivalvonta (Finnish Financial Supervisory Authority, FIN-FSA) imposed a total fine of 70,000 EUR; the admission had a mitigating effect.

What organisations can take from it

Reporting obligations require deadline monitoring with a deputy arrangement – especially in small firms without their own reporting department.

Relevance to training and awareness

Regulatory reporting

Authority / court
Finanssivalvonta (FIN-FSA)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
MiFIR (VO (EU) 600/2014) Art. 26 Abs. 1; IFR (VO (EU) 2019/2033) Art. 54 Abs. 1; FIN-FSA-Vorschriften 20/2013 (FINREP)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Admission of the failures / cooperation.
Published
25 Mar 2026

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

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17 Feb 2026 REGIS-TR S.A.Trade repository REGIS-TR: deficiencies in organisation and data protection – 1.37 million EUR EU levelOrganisational requirements €1.37m

The Luxembourg trade repository lacked adequate compliance procedures and an appropriate organisational structure, failed to identify operational risks and did not adequately protect the confidentiality and integrity of the reported data. ESMA imposed fines totalling 1,374,000 EUR for negligent infringements under EMIR and SFTR; the case is under appeal.

What organisations can take from it

Market infrastructures must manage operational risks and data access as strictly as banks manage their credit risks.

Authority / court
Europäische Wertpapier- und Marktaufsichtsbehörde (ESMA)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Verordnung (EU) Nr. 648/2012 (EMIR), Art. 65, 73, Anhang I; Verordnung (EU) 2015/2365 (SFTR), Art. 9
Action
Fine
Status of proceedings
under appeal
Sector
Financial services and insurance
Culpability
negligent
Repeat case
yes

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

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10 Dec 2025 Invest in OÜLender Invest in OÜ pays 16,000 EUR for failing to submit annual accounts EstoniaDisclosure and reporting obligations €16,000

The lender did not submit its 2024 annual report, together with the audit report, the resolution on the appropriation of profits and the minutes of the shareholders’ meeting, to the financial supervisory authority on time. In misdemeanour proceedings, the Finantsinspektsioon (Estonian Financial Supervision Authority) imposed a fine of 16,000 EUR; the maximum is 1 million EUR or 10% of annual turnover. Date = publication.

What organisations can take from it

Even small supervised lenders need a reliable deadline calendar for mandatory supervisory reports.

Authority / court
Finantsinspektsioon (Estnische Finanzaufsicht)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
§ 56 Abs. 3, § 96 Abs. 2 KAVS (Gesetz über Kreditgeber und -vermittler)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
10 Dec 2025

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

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21 Oct 2025 Taxshelter.be SATaxshelter.be: 75,000 EUR for missing prospectus supplement on guarantee risks BelgiumDisclosure and reporting obligations €75,000

After the tax authority had refused the tax shelter certificates for a financed show and the insurer left cover open, the provider failed to inform investors of this material risk in good time by means of a prospectus supplement. The Autorité des services et marchés financiers (Belgian Financial Services and Markets Authority, FSMA) accepted a settlement of 75,000 EUR with publication by name.

What organisations can take from it

New material risks for investors trigger an immediate obligation to publish a supplement – not only in the next annual prospectus.

Authority / court
Autorité des services et marchés financiers (FSMA)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Verordnung (EU) 2017/1129 Art. 23; Loi du 11 juillet 2018 (Loi Prospectus)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
21 Oct 2025

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

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13 Oct 2025 Wonderinterest Trading LtdCyprus: 100,000 EUR against Wonderinterest Trading over misleading client information CyprusOrganisational requirements €100,000

For 2022 to 2024, the Cyprus Securities and Exchange Commission (CySEC) found that the investment firm had no adequate compliance procedures, did not define target markets for its financial instruments, did not act in the best interests of clients and did not inform clients in a fair, clear and not misleading manner. It imposed fines of 50,000, 30,000 and 20,000 EUR; a judicial review of the decision has been recorded.

What organisations can take from it

Advertising statements by financial service providers must present risks in a balanced way – marketing belongs in the compliance approval process.

Relevance to training and awareness

Fair and not misleading marketing communications

Authority / court
Cyprus Securities and Exchange Commission (CySEC)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Sec. 17(2), 17(3)(c), 22(1), 25(1), 25(3)(a) Gesetz über Wertpapierdienstleistungen 2017; Art. 22, 44 Delegierte VO (EU) 2017/565
Action
Fine
Status of proceedings
under appeal
Sector
Financial services and insurance
Published
17 Dec 2025

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

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13 Oct 2025 Finamore S.A.Finamore: licence of insurance broker withdrawn over serious deficiencies LuxembourgOrganisational requirements Other

The Commissariat aux Assurances (Luxembourg insurance supervisory authority, CAA) withdrew the broking firm’s licence (effective from 1 December 2025), among other things for using unregistered intermediaries, lacking internal expertise, insufficiently protected confidential data, economically unexplained payment flows with affiliated companies, incomplete or false information provided to the supervisory authority and deficient customer information.

What organisations can take from it

False information to the supervisory authority and unregistered distribution partners can cost the business its existence – not just a fine.

Authority / court
Commissariat aux Assurances (CAA)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Loi modifiée du 7 décembre 2015 sur le secteur des assurances, Art. 303 Abs. 3 lit. c
Action
Other
Status of proceedings
unknown
Sector
Financial services and insurance
Published
29 May 2026

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

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16 Sep 2025 Go West Invest SAGo West Invest: 10,000 EUR for outdated information note in tax shelter offering BelgiumDisclosure and reporting obligations €10,000

From June 2021 to October 2024, the company, which raises tax shelter funds through public offerings, kept a public offering on its website with an information note from 2020 without publishing an updated note and filing it with the Autorité des services et marchés financiers (Belgian Financial Services and Markets Authority, FSMA); several dozen investors with an investment volume of under 5 million EUR were affected. The FSMA accepted a settlement of 10,000 EUR.

What organisations can take from it

Investor information has an expiry date – a deadline calendar for mandatory documents prevents infringements.

Authority / court
Autorité des services et marchés financiers (FSMA)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Loi du 11 juillet 2018 (Loi Prospectus), Art. 10, 11
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
16 Sep 2025

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5 Sep 2025 „Paysera LT“, UABPaysera took over e-money institution Contis without approval – 400,000 EUR LithuaniaOrganisational requirements €400,000

Paysera acquired 100% of the shares in UAB ‘Finansinės paslaugos „Contis“’ before the assessment period had expired and without a non-objection from the supervisory authority; in April 2025, the Lietuvos bankas (Bank of Lithuania, financial supervisor) objected to the acquisition owing to a lack of documents on reputation, financial soundness and money laundering risks. In addition, the annual financial statements and other reports were not approved and submitted on time. Fine of 400,000 EUR and obligation to remedy by 30 September 2025. Source: archived copy of the press release.

What organisations can take from it

Complete acquisitions of holdings in supervised institutions only after approval – otherwise voting rights are suspended and fines loom.

Authority / court
Lietuvos bankas (Litauische Zentralbank, Finanzaufsicht)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Elektroninių pinigų ir elektroninių pinigų įstaigų įstatymas (Inhaberkontrolle, Berichtspflichten)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
5 Sep 2025

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1 Sep 2025 Blacktower Financial Management (Cyprus) LtdCyprus: Blacktower Financial Management pays 70,000 EUR over conflicts of interest CyprusOrganisational requirements €70,000

For the period November 2020 to May 2025, the Cyprus Securities and Exchange Commission (CySEC) investigated the investment firm’s handling of conflicts of interest and its general conduct of business and information obligations towards clients. The proceedings ended with a settlement of 70,000 EUR, which the company has paid.

What organisations can take from it

Conflicts of interest must be identified, documented and managed vis-à-vis clients – adviser training is the basis for this.

Relevance to training and awareness

Recognising conflicts of interest in investment advice

Authority / court
Cyprus Securities and Exchange Commission (CySEC)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Art. 24(1), 25(1) Gesetz über Wertpapierdienstleistungen 2017; Art. 37(4) CySEC-Gesetz
Action
Other
Status of proceedings
final
Sector
Financial services and insurance
Published
17 Nov 2025

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23 Jul 2025 Condor Courtiers & Conseillers S.à r.l.Condor Courtiers & Conseillers: licence withdrawn for using unlicensed introducers LuxembourgOrganisational requirements Other

Following an on-site inspection in 2024, the Commissariat aux Assurances (Luxembourg insurance supervisory authority, CAA) withdrew the broker’s licence (effective 15 September 2025): there was no effective management by approved managers, unlicensed ‘introducers’ were de facto selling insurance, and the broker’s licence, together with its sub-intermediary network, was improperly made available to third parties.

What organisations can take from it

A distribution licence is not transferable – anyone who ‘rents it out’ to third parties or lets introducers sell risks having it withdrawn.

Authority / court
Commissariat aux Assurances (CAA)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Loi modifiée du 7 décembre 2015 sur le secteur des assurances, Art. 273, 274, 283, 286, 303
Action
Other
Status of proceedings
unknown
Sector
Financial services and insurance
Published
16 Sep 2025

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8 Jul 2025 Barents Reinsurance S.A.Barents Reinsurance: maximum fine of 250,000 EUR over governance deficiencies LuxembourgOrganisational requirements €250,000

The reinsurer breached the principle of specialisation in reinsurance business, its approved manager was not effectively present on site and had insufficient powers, the governance system including oversight of outsourced functions was inadequate, and orders from a 2019 inspection had not been implemented or only partially. The Commissariat aux Assurances (Luxembourg insurance supervisory authority, CAA) imposed the statutory maximum of 250,000 EUR; the company cooperated.

What organisations can take from it

On-site substance is a supervisory requirement: management, powers and oversight of outsourced functions must genuinely be located in the home country.

Authority / court
Commissariat aux Assurances (CAA)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Loi modifiée du 7 décembre 2015 sur le secteur des assurances, Art. 49, 71, 81, 274, 303
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
Cooperation with the CAA during and after the inspection.
Published
8 Aug 2025

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31 Mar 2025 FXNET LimitedCyprus: FXNET pays 225,000 EUR under settlement over organisational and CFD breaches CyprusOrganisational requirements €225,000

The investigation covering 2021 to 2022 concerned compliance organisation, product governance, record-keeping obligations, safeguarding of client funds, client information, suitability and appropriateness assessments and the CFD restrictions for retail investors. Following board resolutions of 17 and 31 March 2025, the Cyprus Securities and Exchange Commission (CySEC) concluded a settlement of 225,000 EUR, which has been paid.

What organisations can take from it

Safeguarding client funds and keeping proper records are basic duties of every investment firm – gaps quickly add up in a settlement.

Authority / court
Cyprus Securities and Exchange Commission (CySEC)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Art. 17, 22(1), 25, 26(3)(a) Gesetz über Wertpapierdienstleistungen 2017; Art. 42 VO (EU) 600/2014; Art. 37(4) CySEC-Gesetz
Action
Other
Status of proceedings
final
Sector
Financial services and insurance
Published
11 Nov 2025

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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.

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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.

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12 Dec 2024 Leonteq AG (Finanzgruppe Leonteq)Leonteq: distribution via unregulated partners – confiscation of 9.3 million CHF in profits SwitzerlandOrganisational requirements €9.98m

The Swiss Financial Market Supervisory Authority (FINMA) found serious breaches of risk management obligations and of the requirement to guarantee irreproachable business conduct: the financial group monitored its distribution chain inadequately and in some cases worked with dubious, unregulated distributors that sold products in countries not intended for them without authorisation. FINMA ordered governance requirements, the termination of these relationships, the appointment of an audit agent and the confiscation of 9.3 million CHF in profits; the ruling was not yet final at the time of publication.

What organisations can take from it

Anyone who distributes via third parties is liable for their regulatory status – sales partners require due diligence just like customers.

Authority / court
Eidgenössische Finanzmarktaufsicht (FINMA)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Finanzmarktaufsichtsgesetz (FINMAG)
Action
Disgorgement of profits
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
Good cooperation in the proceedings; Leonteq had already strengthened compliance and distribution controls of its own accord and terminated relationships with suspicious distributors

Original amount 9,300,000 CHF, converted at the ECB reference rate of 12 Dec 2024.

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26 Nov 2024 Macquarie Bank Limited, London BranchMacquarie Bank London: 13 million GBP – trader concealed over 400 fictitious trades United KingdomOrganisational requirements €15.6m

From June 2020 to February 2022, a trader on the metals and commodities desk was able to book over 400 fictitious trades and circumvent three key internal controls in order to conceal losses; the bank was partly aware of the weaknesses but did not remedy them in time. Unwinding the positions cost around 57.8 million USD; the Financial Conduct Authority (FCA) imposed 13 million GBP on the bank and banned the trader Travis Klein.

What organisations can take from it

Close known control weaknesses in trading with a deadline and a responsible person – otherwise a lone perpetrator becomes an organisational failure.

Relevance to training and awareness

Recognising and reporting circumvention of controls in trading

Authority / court
Financial Conduct Authority (FCA)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
FCA Principles for Businesses, Principle 3 (Systeme und Kontrollen); s. 206 Financial Services and Markets Act 2000
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Liability of senior managers
Prohibition order imposed on the trader; no fine imposed on him on grounds of serious financial hardship.

Original amount 13,031,400 GBP, converted at the ECB reference rate of 26 Nov 2024.

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22 Nov 2024 Banus Port Vagyonkezelő Zrt.Banus Port: 250 million HUF for fictitious trading in 4iG shares HungaryMarket abuse and insider dealing €608,080

From September 2023 to May 2024, the asset management company used transactions worth several billion forints to create false signals about the trading volume of 4iG shares (‘painting the tape’). The Magyar Nemzeti Bank (Central Bank of Hungary, MNB) prohibited any repetition, imposed 250 million HUF and filed a criminal complaint.

What organisations can take from it

Transactions that mainly simulate turnover are market manipulation – even without a price target.

Authority / court
Magyar Nemzeti Bank (MNB)
Area of law
Capital markets and financial supervision · Market abuse and insider dealing
Legal basis
Art. 12, 15 MAR (Marktmanipulation), Beschluss H-PJ-III-B-26/2024
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Culpability
intentional
Published
22 Nov 2024

Original amount 250,000,000 HUF, converted at the ECB reference rate of 22 Nov 2024.

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6 Nov 2024 Deželna banka Slovenije d. d.Deželna banka Slovenije: 90,000 EUR for deficient credit risk provisioning SloveniaOrganisational requirements €90,000

From 2018 to mid-2023, the bank had no adequate policies for impairments and provisions under IFRS 9 and the EBA guidelines on credit risk. Banka Slovenije (Bank of Slovenia) imposed 90,000 EUR on the bank and 2,500 EUR each on the chair of the management board and a board member.

What organisations can take from it

In Slovenia, governance deficiencies in risk management are also sanctioned personally against board members.

Authority / court
Banka Slovenije
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Art. 171, Art. 396 Abs. 1 Nr. 19 ZBan-3
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Liability of senior managers
Fines of 2,500 EUR each on the chair of the management board, Marko Rozman, and the board member Barbara Cerovšek Zupančič.

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20 Mar 2024 Scope Ratings GmbHScope Ratings: conflicts of interest not identified and disclosed – 2.2 million EUR EU levelOrganisational requirements €2.2m

The Berlin-based credit rating agency lacked adequate procedures, internal controls and organisational arrangements to deal with conflicts of interest, did not disclose a potential conflict and concealed ancillary services it had provided to a rated entity. ESMA found negligent infringements and imposed fines of 2,197,500 EUR.

What organisations can take from it

Systematically record and disclose ancillary services for customers whom you are at the same time rating or auditing.

Relevance to training and awareness

Identifying and disclosing conflicts of interest

Authority / court
Europäische Wertpapier- und Marktaufsichtsbehörde (ESMA)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Verordnung (EG) Nr. 1060/2009 (CRA-Verordnung), Anhang III
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Culpability
negligent
Repeat case
yes
Published
22 Mar 2024

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