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.

29cases from 1 jurisdiction
€1.17bnTotal of monetary amounts
€19.8mMedian per case with an amount

Click a bar to drill down one level.

When?

per year, by date of decision
Trend
PeriodCasesTotal
20221€77.8m
20237€355.8m
202411€520.5m
20255€132.6m
20265€86.7m

29 cases

31 Jul 2026 UBS Financial Services Inc.UBS Financial Services: 8 million USD over gaps in anti-money laundering monitoring USAOrganisational requirements €6.97m

The CFTC fined the futures commission merchant 8 million USD for failing to supervise diligently the configuration and operation of its anti-money laundering transaction monitoring. From January 2019 to June 2023, thousands of foreign currency wire transfers through retail customers' commodity accounts were insufficiently monitored or not monitored at all: first because of an incomplete manual report which UBS, contrary to commitments made in earlier proceedings in 2018, replaced only more than two years later, and then because of incorrectly fed data in the new automated system. FinCEN, the SEC and FINRA announced their own settlements with UBS Financial Services at the same time. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

Commitments made in earlier supervisory proceedings must be implemented on time, and new monitoring systems must be tested for complete data feeds before going live.

Authority / court
U.S. Commodity Futures Trading Commission (CFTC)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
CFTC Regulation 166.3 (17 C.F.R. § 166.3)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Repeat case
yes
Mitigating circumstances
The CFTC recognised the remediation described; according to the order, the core problems of the automated system had been fixed by the fourth quarter of 2022.
Published
3 Aug 2026

Original amount 8,000,000 USD, converted at the ECB reference rate of 31 Jul 2026.

Checked against the official source on 3 Oct 2026 · Direct link

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16 Jul 2026 Swedbank AB (publ) (mit New York Branch)NYDFS: USD 50 million against Swedbank for withholding information USA, New YorkDisclosure and reporting obligations €43.6m

The NYDFS imposed a penalty of USD 50 million on Swedbank AB (publ) and its New York branch. In response to several requests by the regulator under section 37 of the New York Banking Law concerning links between its Baltic subsidiaries and the law firm Mossack Fonseca (Panama Papers) and the status of European investigations, the bank did not provide the requested information, in breach of section 125(3) of the New York Banking Law. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

Information requests from the regulator must be answered in full; withholding information is sanctioned in its own right.

Relevance to training and awareness

Complete and truthful disclosures to the regulator

Authority / court
New York State Department of Financial Services (NYDFS)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
New York Banking Law § 125(3) i. V. m. § 37; Sanktion nach Banking Law §§ 39, 44
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Liability of senior managers
According to the order, the bank has since, among other things, dismissed its then Chief Compliance Officer and its former CEO and parted ways with numerous other employees; the majority of the board has been replaced.
Published
16 Jul 2026

Original amount 50,000,000 USD, converted at the ECB reference rate of 16 Jul 2026.

Checked against the official source on 3 Oct 2026 · Direct link

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26 Jun 2026 Netrios LP Ltd.; Red Acre Ltd.Netrios and Red Acre: 2.5 million USD for white-label leveraged trading with US retail customers USAOrganisational requirements €2.19m

The CFTC fined Netrios LP Ltd., incorporated in Saint Lucia, 1,750,000 USD and Maltese Red Acre Ltd. 750,000 USD, totalling 2,500,000 USD. From 2019 to September 2025, Netrios sold a white-label service (website, trading software, margin accounts, execution, back office) through which offshore platforms offered US retail customers who were not eligible contract participants leveraged forex, precious metals, crypto and equity transactions outside a registered exchange; Red Acre assisted with customer support and marketing. The SEC took parallel action over the same conduct. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

Technology and service providers share liability if their platform solution enables US retail customers to trade on leverage unlawfully outside registered exchanges.

Authority / court
U.S. Commodity Futures Trading Commission (CFTC)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Section 4(a) Commodity Exchange Act (7 U.S.C. § 6(a)); Beihilfe nach Section 13(a) (7 U.S.C. § 13c(a))
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
29 Jun 2026

Original amount 2,500,000 USD, converted at the ECB reference rate of 26 Jun 2026.

Checked against the official source on 3 Oct 2026 · Direct link

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30 Mar 2026 Peken Global Limited (KuCoin)Peken Global (KuCoin): 500,000 USD and ban on US access without CFTC registration USAOrganisational requirements €435,388

On a complaint by the CFTC, the federal court in New York entered a consent order against the operator of the KuCoin crypto exchange, which is registered in the Turks and Caicos Islands. Peken Global had given US participants direct access to its trading system without being registered with the CFTC as a foreign board of trade; the court permanently prohibited this and imposed a fine of 500,000 USD. Disgorgement was waived because of the cooperation and the forfeiture in the parallel criminal case, in which Peken Global had pleaded guilty to operating an unlicensed money transmitting business. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

Anyone giving US participants direct access to a foreign trading platform needs the appropriate CFTC registration or must effectively block such access.

Authority / court
U.S. District Court for the Southern District of New York (auf Klage der CFTC)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
CFTC Regulation 48.3 (17 C.F.R. § 48.3); Section 6c Commodity Exchange Act (7 U.S.C. § 13a-1)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Cooperation with the CFTC and in the criminal proceedings; because of the forfeiture ordered there, the CFTC did not seek disgorgement.
Published
30 Mar 2026

Original amount 500,000 USD, converted at the ECB reference rate of 30 Mar 2026.

Checked against the official source on 3 Oct 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 €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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17 Sep 2025 Shinhan Securities Co. Ltd.Shinhan Securities: 212,500 USD for 127 wash trades in crude oil futures on NYMEX USAMarket abuse and insider dealing €179,522

Between March 2023 and February 2024 a trader at the Korean financial services firm placed near-simultaneous opposing orders for accounts with the same beneficial owner, so that 127 trades in 440 crude oil futures (around 33.5 million USD) offset each other, some of them against orders from traders on other desks of the firm. The CFTC (U.S. Commodity Futures Trading Commission) treated this as prohibited wash sales and non-competitive trades and, in a settlement, imposed a civil monetary penalty of 212,500 USD and a cease-and-desist order; it granted a 20% reduction for excellent cooperation. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

Trade surveillance must catch trades in which orders from different accounts or desks of the same firm meet – such self-matches are quickly treated as wash trades.

Relevance to training and awareness

Prohibition of wash trades and self-matching between a firm's own accounts and desks

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; CFTC Regulation 1.38(a)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Culpability
intentional
Mitigating circumstances
Excellent cooperation with the Division of Enforcement (20% reduction of the penalty); the CFTC also acknowledged the company's representations regarding its remedial measures.
Published
17 Sep 2025

Original amount 212,500 USD, converted at the ECB reference rate of 17 Sep 2025.

Checked against the official source on 3 Oct 2026 · Direct link

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9 Sep 2025 Flatiron Futures Traders, LLCFlatiron Futures Traders: 200,000 USD for spoofing in E-mini futures USAMarket abuse and insider dealing €170,300

The CFTC imposed a fine of 200,000 USD on the Illinois trading firm. Measures against individuals are not set out here. From May to December 2022, orders were placed for Flatiron in E-mini S&P 500 and E-mini Nasdaq 100 futures on the CME that were intended to be cancelled before execution, so that the genuine orders on the opposite side were filled faster, in larger quantities or at better prices. The spoof orders exceeded the genuine orders in contract volume by a ratio of five to one. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

Trading firms are liable for their traders' spoofing; cancellation ratios and one-sided order patterns belong in ongoing surveillance.

Relevance to training and awareness

Recognising and preventing spoofing in proprietary trading

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)(5)(C) Commodity Exchange Act (7 U.S.C. § 6c(a)(5)(C))
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Culpability
intentional
Liability of senior managers
Measures against individuals are not set out here.
Published
9 Sep 2025

Original amount 200,000 USD, converted at the ECB reference rate of 9 Sep 2025.

Checked against the official source on 3 Oct 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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6 Jan 2025 Gemini Trust Company, LLCGemini Trust: 5 million USD over misleading statements to the CFTC USADisclosure and reporting obligations €4.8m

On a complaint by the CFTC, the federal court in New York ordered the New York trust company, in a consent order, to pay a fine of 5 million USD and imposed a permanent injunction. In 2017, in connection with the self-certification of a bitcoin futures contract that referenced an auction on Gemini, Gemini made statements to the CFTC, or omitted facts, that it should reasonably have known were false or misleading, for example on its prefunding requirement, self-trade prevention, fee rebates and trading volume and liquidity. These statements were material to the assessment of whether the contract was susceptible to manipulation. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

What a company tells the supervisor to assess a product must be complete and reliable; statements made by its representatives are attributed to it.

Relevance to training and awareness

Truthful statements to supervisory authorities

Authority / court
U.S. District Court for the Southern District of New York (auf Klage der CFTC)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Section 6(c)(2) Commodity Exchange Act (7 U.S.C. § 9(2))
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
13 Jan 2025

Original amount 5,000,000 USD, converted at the ECB reference rate of 6 Jan 2025.

Checked against the official source on 3 Oct 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 28 Sep 2026 · Version 2 · 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 28 Sep 2026 · Version 2 · 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 28 Sep 2026 · Version 2 · Direct link

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30 Sep 2024 a registered swap dealerCFTC: USD 4 million for misreporting more than five million swaps USADisclosure and reporting obligationsanonymised €3.57m

The CFTC fined the registered swap dealer 4 million USD. From 2018 to 2023 the firm reported more than five million swap transactions incorrectly or late, among other things because of a duplicate swap identifier, incorrect primary economic terms and time stamps, and errors in continuation data reporting. The firm admitted the facts; the fine was lower because of substantial cooperation and remediation. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

Derivatives reporting chains need ongoing data quality controls; firms that report errors themselves can significantly reduce the sanction.

Authority / court
U.S. Commodity Futures Trading Commission (CFTC)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Sections 2(a)(13) und 4r(a)(3) Commodity Exchange Act; CFTC Regulations 43.3 und 45.3–45.4
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Published
1 Oct 2024

Original amount 4,000,000 USD, converted at the ECB reference rate of 30 Sep 2024.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 30 Sep 2026 · 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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28 Aug 2024 a former US futures exchangeFormer futures exchange: 22 million USD over hidden volume incentives and false statements USADisclosure and reporting obligationsanonymised €19.8m

The CFTC fined the former designated contract market 22 million USD. Between 2015 and 2018, the exchange made volume-based payments to certain participants in its market maker programme on top of the disclosed fixed stipend, did not disclose this to the CFTC, the public, its own compliance staff or its regulatory service provider, and made false and misleading statements to the CFTC about it. It also failed to follow its regulatory service provider's recommendation concerning certain trading activity and did not record why.

What organisations can take from it

A trading venue's incentive programmes must be fully disclosed and known to its own compliance function; inaccurate information given to the supervisor is a separate breach.

Relevance to training and awareness

Truthful and complete statements to supervisory authorities

Authority / court
U.S. Commodity Futures Trading Commission (CFTC)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Sections 5(d)(2), 5(d)(7), 5(d)(12) und 6(c)(2) Commodity Exchange Act; CFTC Regulations 38.150, 38.154(c), 38.400, 38.401(b), 38.650, 38.651, 38.4(b) und 40.6
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
29 Aug 2024

Original amount 22,000,000 USD, converted at the ECB reference rate of 28 Aug 2024.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 28 Aug 2026 · Direct link

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27 Aug 2024 the trading subsidiary of a European energy groupEnergy group's trading subsidiary: attempted manipulation of gasoline futures USAMarket abuse and insider dealinganonymised €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 28 Sep 2026 · Version 4 · Company name anonymised since 27 Aug 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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17 Jun 2024 a US trading company of an international commodity trading groupCommodity trader: 55 million USD for third-party inside information, benchmark manipulation, gagging NDAs USAMarket abuse and insider dealinganonymised €51.3m

From 2014 to April 2019 the US trading company of an international commodity trading group traded gasoline while in possession of confidential information that an employee of a Mexican trading entity had passed on in breach of his duties, and in February 2017 it artificially pushed up the USGC HSFO benchmark by buying 80 cargoes of fuel oil (3.6 million barrels) in the Platts trading window to benefit its own derivatives positions. In addition, broadly drafted confidentiality clauses in employment and separation agreements (2017–2020) hindered employees from contacting the CFTC (U.S. Commodity Futures Trading Commission) directly – according to the regulator, its first action of this kind against a company. Under a settlement, the trader pays a civil monetary penalty of 55,000,000 USD and must amend the clauses.

What organisations can take from it

Confidentiality clauses need an express carve-out for reports to the authorities, and market information from other firms must be checked for its origin before trading on it.

Relevance to training and awareness

Handling third parties' confidential information in commodity trading; not blocking reporting channels to authorities by contract

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 6(c)(1) und Section 23(h)–(j) Commodity Exchange Act; CFTC Regulations 180.1(a)(1), (3) und 165.19
Action
Fine
Status of proceedings
final
Sector
Energy and utilities
Mitigating circumstances
According to the trader, it voluntarily took remedial action (market integrity policies, controls on market-related communications, more training and compliance testing).
Published
17 Jun 2024

Original amount 55,000,000 USD, converted at the ECB reference rate of 17 Jun 2024.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 17 Jun 2026 · Direct link

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