Compliance Radar

Who was sanctioned, and for what?

Fines, court rulings and incidents from Europe, North America, Latin America, Asia-Pacific, Middle East and Africa: 2,207 cases from 44 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.

5cases from 1 jurisdiction
€41.3mTotal of monetary amounts
€33.5mLargest single case: Archer-Daniels-Midland Company (ADM)
€2.83mMedian per case with an amount

Click a bar to drill down one level.

Where?

by region

All jurisdictions

  1. USA €41.3m 100 % · 5 cases

What for?

by topic
  1. Disclosure and reporting obligations €37.8m 92 % · 3 cases
  2. Market abuse and insider dealing €3.51m 8 % · 2 cases

Who?

by company
  1. Archer-Daniels-Midland Company (ADM) €33.5m 81 % · 1 case
  2. Anonymised companies €7.78m 19 % · 4 cases

When?

per year, by date of decision
Trend
PeriodCasesTotal
20231€2.83m
20243€4.95m
20250–
20261€33.5m

5 cases

27 Jan 2026 Archer-Daniels-Midland Company (ADM)ADM: embellished segment results in Nutrition – 40 million USD penalty USADisclosure and reporting obligations €33.5m

ADM had artificially inflated the results of the Nutrition segment through retroactive intra-group rebates and price adjustments in order to show growth targets of 15 to 20 %. ADM is paying a civil penalty of 40 million USD.

What organisations can take from it

Intra-group transfer prices and retroactive segment adjustments require independent control when segments are publicly promoted as growth drivers.

Authority / court
U.S. Securities and Exchange Commission (SEC)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Antifraud-, Reporting-, Buchführungs- und interne Kontrollvorschriften der US-Bundeswertpapiergesetze (Settled Order der SEC)
Action
Fine
Status of proceedings
unknown
Sector
Food and agriculture
Mitigating circumstances
ADM's cooperation and remedial measures were taken into account
Liability of senior managers
Measures against individuals are not reported here.

Original amount 40,000,000 USD, converted at the ECB reference rate of 27 Jan 2026.

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

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27 Sep 2024 a Singapore-based agricultural supply chain companyAgricultural trader: 3.25 million USD over late reporting of cotton sales USADisclosure and reporting obligationsanonymised €2.91m

The CFTC fined the Singapore-based agricultural supply chain company 3,250,000 USD. In August and September 2021, subsidiaries reported five sales of more than 375,000 bales of US cotton worth over 190 million USD to an Asian buyer to the US Department of Agriculture one to five weeks late, and left them out of seven Form 304 reports to the CFTC. According to the order, this happened knowingly or recklessly, although the company knew that such sales data affects the price of cotton.

What organisations can take from it

Reportable sales must go into regulatory reports straight away, especially large, market-moving transactions.

Relevance to training and awareness

Timely and complete regulatory reporting to authorities

Authority / court
U.S. Commodity Futures Trading Commission (CFTC)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Section 6(c)(1)(A) Commodity Exchange Act (7 U.S.C. § 9(1)(A)); CFTC Regulations 19.02(a) und 180.1(a)(4); frühere CFTC Regulation 19.01(a) (17 C.F.R. § 19.01(a) (2020))
Action
Fine
Status of proceedings
final
Sector
Food and agriculture
Mitigating circumstances
The CFTC recognised the company's cooperation with the investigation and the remediation it described.
Published
27 Sep 2024

Original amount 3,250,000 USD, converted at the ECB reference rate of 27 Sep 2024.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 27 Sep 2026 · Direct link

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10 Sep 2024 a US beverage groupBeverage group: inaccurate recyclability statements on coffee pods in the annual report USADisclosure and reporting obligationsanonymised €1.36m

In its 2019 and 2020 annual reports, the group claimed that tests confirmed the recyclability of its coffee pods, but failed to disclose that two of the largest US recycling companies had expressed significant concerns and stated that they did not currently intend to accept the pods. The group is paying a civil penalty of 1.5 million USD.

What organisations can take from it

Sustainability statements in mandatory reports must be complete – known objections from customers are part of this.

Authority / court
U.S. Securities and Exchange Commission (SEC)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Section 13(a) Securities Exchange Act 1934, Rule 13a-1
Action
Fine
Status of proceedings
final
Sector
Food and agriculture

Original amount 1,500,000 USD, converted at the ECB reference rate of 10 Sep 2024.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 10 Sep 2026 · Direct link

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19 Aug 2024 two companies of a Brazilian sugar and energy groupSugar group: 750,000 USD over intra-group wash sales in sugar futures USAMarket abuse and insider dealinganonymised €679,286

The CFTC imposed a fine of 750,000 USD, jointly and severally, on a Brazilian and a Swiss company of a Brazilian sugar and energy group. From March to September 2022, the two group companies executed 44 exchange for physical transactions in sugar futures on a US futures exchange between accounts that were not independently controlled, in order to transfer physical sugar within the group; the CFTC treated them as prohibited wash sales and non-competitive transactions. More than 50,000 contracts worth over 1 billion USD were involved; the companies admitted the facts.

What organisations can take from it

Intra-group transfers through the exchange are wash sales if both sides are not independently controlled; other routes are needed for them.

Relevance to training and awareness

Wash sales and intra-group exchange transactions

Missing or inadequate training played a role in the decision.

Authority / court
U.S. Commodity Futures Trading Commission (CFTC)
Area of law
Capital markets and financial supervision · Market abuse and insider dealing
Legal basis
Section 4c(a)(1) und (2)(A) Commodity Exchange Act (7 U.S.C. § 6c(a)(1), (2)(A)); CFTC Regulation 1.38(a)
Action
Fine
Status of proceedings
final
Sector
Food and agriculture
Mitigating circumstances
The CFTC acknowledged the remediation described: stopping intra-group EFPs, a written compliance manual, training on US law, annual training programmes and additional compliance staff.
Published
19 Aug 2024

Original amount 750,000 USD, converted at the ECB reference rate of 19 Aug 2024.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 19 Aug 2026 · Direct link

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23 Oct 2023 a US grain merchandiserGrain merchandiser: 3 million USD for attempted manipulation of oats futures USAMarket abuse and insider dealinganonymised €2.83m

The CFTC fined a grain merchandiser from Minnesota 3 million USD for attempted manipulation of the July 2016 and March 2017 oats futures contracts. According to the order, with the knowledge of senior personnel, the merchandiser built up large long positions close to the speculative position limits, held them into the delivery period and took delivery of oats, intending to raise the futures price and obtain better-quality oats at lower delivery prices. The CFTC recognised significant remedial measures.

What organisations can take from it

Holding futures positions into the delivery period in order to influence the price is manipulation – even in small agricultural markets.

Relevance to training and awareness

Market manipulation in commodity and futures trading

Missing or inadequate training played a role in the decision.

Authority / court
U.S. Commodity Futures Trading Commission (CFTC)
Area of law
Capital markets and financial supervision · Market abuse and insider dealing
Legal basis
Section 9(a)(2) Commodity Exchange Act (7 U.S.C. § 13(a)(2))
Action
Fine
Status of proceedings
final
Sector
Food and agriculture
Culpability
intentional
Mitigating circumstances
According to the order, the merchandiser revised its policies and procedures and introduced training for all personnel trading commodity interests.
Published
23 Oct 2023

Original amount 3,000,000 USD, converted at the ECB reference rate of 23 Oct 2023.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 23 Oct 2025 · Direct link

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