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 (SEC) €400.8m 90 % · 8 cases
- U.S. Commodity Futures Trading Commission (CFTC) €43m 10 % · 1 case
What for?
by topicWho?
by sectorAll sectors
When?
per quarter, by date of decision| Period | Cases | Total |
|---|---|---|
| Q3 2023 | 1 | €23.9m |
| Q4 2023 | 0 | — |
| Q1 2024 | 0 | — |
| Q2 2024 | 0 | — |
| Q3 2024 | 2 | €44.4m |
| Q4 2024 | 3 | €213.6m |
| Q1 2025 | 2 | €127.5m |
| Q2 2025 | 0 | — |
| Q3 2025 | 0 | — |
| Q4 2025 | 0 | — |
| Q1 2026 | 1 | €34.5m |
| Q2 2026 | 0 | — |
| Q3 2026 | 0 | — |
9 cases
27 Jan 2026 Archer-Daniels-Midland Company (ADM)ADM: embellished segment results in Nutrition – 40 million USD penalty €34.5m
ADM and former executives had artificially inflated the results of the Nutrition segment through retroactive intra-group rebates and price adjustments in order to show growth targets of 15–20 %. ADM is paying a civil penalty of 40 million USD; two former managers are paying a combined 979,953 USD in disgorgement including interest and 200,000 USD in penalties, while litigation continues against a third.
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
- Vince Macciocchi: 404,343 USD disgorgement/interest, 125,000 USD penalty, 3-year officer-and-director bar; Ray Young: 575,610 USD disgorgement/interest, 75,000 USD penalty; action against Vikram Luthar pending
Original amount 41,179,953 USD, converted at the ECB reference rate of 27 Jan 2026.
- SEC Charges ADM and Three Former Executives with Accounting and Disclosure Fraud Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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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 €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.
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.
- SEC Charges Two Sigma for Failing to Address Known Vulnerabilities in its Investment Models (16.01.2025) Press release of an authority
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 €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.
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.
- SEC Charges BMO Capital Markets with Failing to Supervise Agency Bond Desk (13.01.2025) Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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16 Dec 2024 Becton, Dickinson and Company (BD)Becton Dickinson: risks of Alaris infusion pump concealed – 175 million USD €166.7m
The medical technology manufacturer misled investors about regulatory risks of the Alaris infusion pump, which had more than 25 software defects, and did not record the remediation costs, as a result of which operating income in the fourth quarter of 2019 was overstated by 82 %. BD is paying 175 million USD and must appoint an independent compliance consultant.
Product and approval problems are capital market issues: quality and regulatory affairs departments must be involved in the disclosure process.
- 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-, interne Kontroll- und Disclosure-Controls-Vorschriften der US-Wertpapiergesetze
- Action
- Fine
- Status of proceedings
- final
- Sector
- Healthcare
Original amount 175,000,000 USD, converted at the ECB reference rate of 16 Dec 2024.
- Becton Dickinson to Pay $175 Million for Misleading Investors About Alaris Infusion Pump Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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22 Nov 2024 United Parcel Service Inc. (UPS)UPS: goodwill of UPS Freight division incorrectly valued – 45 million USD €43.2m
UPS based the valuation of UPS Freight on a consultant's appraisal of around 2 billion USD, although its own analyses had arrived at only about 650 million USD, and did not record a required goodwill impairment. UPS is paying 45 million USD and must introduce training for certain executives, board members and employees and engage an independent compliance consultant.
Valuation reports are only as good as the information given to the valuers – internal findings must feed into impairment tests.
- Authority / court
- U.S. Securities and Exchange Commission (SEC)
- Area of law
- Capital markets and financial supervision · Disclosure and reporting obligations
- Legal basis
- Section 17(a)(2),(3) Securities Act; Reporting-, Buchführungs-, interne Kontroll- und Disclosure-Controls-Vorschriften des Exchange Act
- Action
- Fine
- Status of proceedings
- final
- Sector
- Transport, logistics and shipping
Original amount 45,000,000 USD, converted at the ECB reference rate of 22 Nov 2024.
- UPS to Pay $45 Million Penalty for Improperly Valuing Business Unit Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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22 Oct 2024 Unisys Corp.SEC: $4 million against Unisys for downplaying cyber incidents after SolarWinds €3.7m
In mandatory disclosures, Unisys presented cyber risks as hypothetical, although it had suffered two intrusions with data exfiltration connected with the SolarWinds compromise. On the same day, the US Securities and Exchange Commission (SEC) also imposed penalties on Avaya ($1 million), Check Point ($995,000) and Mimecast ($990,000).
Do not describe cyber incidents that have occurred as a mere risk in investor information – disclosure processes must involve IT security.
- Authority / court
- U.S. Securities and Exchange Commission (SEC)
- Area of law
- Capital markets and financial supervision · Disclosure and reporting obligations
- Legal basis
- Securities Act of 1933, Securities Exchange Act of 1934 (inkl. Disclosure Controls)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Telecoms, IT and software
- Culpability
- negligent
- Mitigating circumstances
- Cooperation in the proceedings and improvement of cybersecurity controls.
- Published
- 22 Oct 2024
Original amount 4,000,000 USD, converted at the ECB reference rate of 22 Oct 2024.
- SEC Charges Four Companies With Misleading Cyber Disclosures Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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10 Sep 2024 Keurig Dr Pepper Inc.Keurig Dr Pepper: inaccurate statements on the recyclability of K-Cups in the annual report €1.36m
In its 2019 and 2020 annual reports, Keurig claimed that tests confirmed the recyclability of the K-Cup 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. Keurig is paying a civil penalty of 1.5 million USD.
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.
- SEC Charges Keurig with Making Inaccurate Statements Regarding Recyclability of K-Cup Beverage Pod Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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27 Aug 2024 TOTSA TotalEnergies Trading SATotalEnergies trading subsidiary: attempted manipulation of gasoline futures €43m
The trading company sold physical gasoline below the bids in order to depress the benchmark price and thereby benefit its short positions in EBOB-related futures. Under the settlement, it is paying a civil penalty of 48 million USD.
Monitor physical trading and derivatives positions together, because manipulation often takes place via the benchmark price.
Market manipulation in commodities trading (physical transactions to benefit derivatives positions)
- Authority / court
- U.S. Commodity Futures Trading Commission (CFTC)
- Area of law
- Capital markets and financial supervision · Market abuse and insider dealing
- Legal basis
- Commodity Exchange Act und CFTC-Regulations (versuchte Marktmanipulation)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Energy and utilities
Original amount 48,000,000 USD, converted at the ECB reference rate of 27 Aug 2024.
- CFTC Orders Swiss Energy Trader to Pay $48 Million for Attempted Market Manipulation Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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26 Sep 2023 Hyzon Motors Inc.Hyzon Motors: fictitious vehicle sales after SPAC merger – 25 million USD €23.9m
The manufacturer of hydrogen commercial vehicles misled investors about customer relationships and sales, reported 87 vehicles sold for 2021 when the actual number was zero, and showed a misleading video of a purportedly hydrogen-powered vehicle. Hyzon is paying 25 million USD, the former CEO 100,000 USD and a former managing director of the European subsidiary 200,000 USD.
After a SPAC merger, the same duties of truthfulness apply as for any issuer – letters of intent must not be sold as revenue.
- Authority / court
- U.S. Securities and Exchange Commission (SEC)
- Area of law
- Capital markets and financial supervision · Disclosure and reporting obligations
- Legal basis
- Antifraud- und weitere Vorschriften der US-Wertpapiergesetze
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Automotive
- Liability of senior managers
- Craig M. Knight (former CEO): 100,000 USD, 5-year officer-and-director bar; Max C.B. Holthausen (former managing director of the European subsidiary): 200,000 USD, 10-year officer-and-director bar
Original amount 25,300,000 USD, converted at the ECB reference rate of 26 Sep 2023.
- SEC Charges Hydrogen Vehicle Co. Hyzon Motors and Two Former Executives for Misleading Investors Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link