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.

12cases from 1 jurisdiction
€446mTotal of monetary amounts
€166.7mLargest single case: Becton, Dickinson and Company (BD)
€29.2mMedian per case with an amount

Click a bar to drill down one level.

When?

per quarter, by date of decision
Trend
PeriodCasesTotal
Q3 20231€23.9m
Q4 20230—
Q1 20240—
Q2 20240—
Q3 20242€44.4m
Q4 20243€213.6m
Q1 20253€129.2m
Q2 20250—
Q3 20250—
Q4 20250—
Q1 20261€34.5m
Q2 20261€288,298
Q3 20261€148,191

12 cases

28 Aug 2026 Insider trading in event contracts: White House teleprompter operator USAMarket abuse and insider dealing €148,191

Between December 2025 and February 2026, Gabriel Perez, a White House teleprompter operator, used confidential information from presidential speeches to trade event contracts on prediction markets. The U.S. Commodity Futures Trading Commission (CFTC) ordered disgorgement of 107,539.02 USD, a penalty of 65,000 USD and a three-year trading ban.

What organisations can take from it

Insider policies should explicitly also cover bets and event contracts on prediction markets.

Relevance to training and awareness

Confidentiality and trading bans when accessing non-public information, including for prediction markets

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 (Missbrauch vertraulicher Informationen)
Action
Fine
Status of proceedings
final
Sector
Public sector
Mitigating circumstances
Substantial reduction for exemplary cooperation under the CFTC's new cooperation policy

Original amount 172,539.02 USD, converted at the ECB reference rate of 28 Aug 2026.

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

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6 Apr 2026 Caroline J. Campbell (Beschäftigte der ImmunityBio, Inc.)ImmunityBio employee sells shares ahead of news of FDA delay USAMarket abuse and insider dealing €288,298

In May 2023, an employee of the biotech company sold 48,495 shares with knowledge of the non-public information that the FDA would delay approval of the medicine Anktiva; after the announcement, the share price fell by around 55 %. Under the settlement, she is paying 157,066.28 USD in disgorgement, 18,130.97 USD in interest and a civil penalty of 157,066.28 USD.

What organisations can take from it

Trading bans and blackout periods must be known to all employees with access to approval or trial data, not just to the management board.

Relevance to training and awareness

Insider trading ban for employees, handling of approval information

Authority / court
U.S. Securities and Exchange Commission (SEC)
Area of law
Capital markets and financial supervision · Market abuse and insider dealing
Legal basis
Section 10(b) Securities Exchange Act 1934, Rule 10b-5
Action
Fine
Status of proceedings
final
Sector
Chemicals and pharmaceuticals

Original amount 332,263.53 USD, converted at the ECB reference rate of 2 Apr 2026.

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

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

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
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.

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 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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10 Jan 2025 Vince McMahon (ehem. Executive Chairman und CEO der World Wrestling Entertainment Inc.)WWE founder McMahon conceals settlement payments from the board and auditors USADisclosure and reporting obligations €1.68m

In 2019 and 2022, the former Executive Chairman and CEO Vince McMahon concluded settlements of 3 million and 7.5 million USD on behalf of WWE without informing the board, the legal department, the accounting function or the auditors; WWE had to restate its financial statements. McMahon is paying a civil penalty of 400,000 USD and reimbursing WWE 1,330,915.90 USD under SOX 304(a).

What organisations can take from it

Payments and settlements that personally concern top management must never be concluded without involving the board and the finance function.

Authority / court
U.S. Securities and Exchange Commission (SEC)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Securities Exchange Act 1934 (Umgehung interner Kontrollen, irreführende Angaben gegenüber Prüfern); Sarbanes-Oxley Act Section 304(a)
Action
Fine
Status of proceedings
final
Sector
Media and online platforms
Liability of senior managers
Vince McMahon (former Executive Chairman and CEO): 400,000 USD penalty and reimbursement of 1,330,915.90 USD to WWE

Original amount 1,730,915.9 USD, converted at the ECB reference rate of 10 Jan 2025.

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 USADisclosure and reporting obligations €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.

What organisations can take from it

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.

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 USADisclosure and reporting obligations €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.

What organisations can take from it

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.

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 USADisclosure and reporting obligations €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).

What organisations can take from it

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.

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 USADisclosure and reporting obligations €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.

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 25 Sep 2026 · Direct link

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27 Aug 2024 TOTSA TotalEnergies Trading SATotalEnergies trading subsidiary: attempted manipulation of gasoline futures USAMarket abuse and insider dealing €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.

What organisations can take from it

Monitor physical trading and derivatives positions together, because manipulation often takes place via the benchmark price.

Relevance to training and awareness

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.

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 USADisclosure and reporting obligations €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.

What organisations can take from it

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.

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

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