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.
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per year, by date of decision| Period | Cases | Total |
|---|---|---|
| 2022 | 1 | €77.8m |
| 2023 | 7 | €355.8m |
| 2024 | 11 | €520.5m |
| 2025 | 5 | €132.6m |
| 2026 | 5 | €86.7m |
29 cases
31 Jul 2026 UBS Financial Services Inc.UBS Financial Services: 8 million USD over gaps in anti-money laundering monitoring €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.
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.
- CFTC Release No. 9277-26: CFTC Orders UBS Financial Services Inc. to Pay $8 Million for Supervision Failures Impacting Its AML Transaction Monitoring Systems (03.08.2026) Press release of an authority
- CFTC Docket No. 26-04, In the Matter of UBS Financial Services Inc., Order Instituting Proceedings (31.07.2026) Decision of an authority
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 €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.
Information requests from the regulator must be answered in full; withholding information is sanctioned in its own right.
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 €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.
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.
- CFTC Release No. 9263-26: CFTC Orders Two Foreign Firms to Pay $2.5 Million for Illegal Off-Exchange Transactions with U.S. Customers (29.06.2026) Press release of an authority
- CFTC Docket No. 26-02, In the Matter of Netrios LP Ltd. and Red Acre Ltd., Order Instituting Proceedings (26.06.2026) Decision of an authority
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 €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.
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.
- CFTC Release No. 9203-26: Federal Court Enters Permanent Injunction Against Peken Global Limited (30.03.2026) Press release of an authority
- U.S. District Court S.D.N.Y., CFTC v. Mek Global Limited et al., No. 24-cv-2255, Consent Order against Peken Global Limited (so ordered 30.03.2026) Court decision
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 €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.
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.
- SEC, Pressemitteilung 2026-15 zu Archer-Daniels-Midland (Entscheidung 2026) Press release of an authority
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 €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.
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.
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.
- CFTC Docket No. 25-08: Order Instituting Proceedings … In the Matter of Shinhan Securities Co. Ltd. (dated 17 September 2025) Decision of an authority
- CFTC Release 9125-25: CFTC Sanctions Trading Firm $212,500 for Wash Sales (17 September 2025) Press release of an authority
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 €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.
Trading firms are liable for their traders' spoofing; cancellation ratios and one-sided order patterns belong in ongoing surveillance.
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.
- CFTC Release No. 9118-25: CFTC Sanctions Colorado Trader and Illinois Company to Pay $200,000 for Spoofing (09.09.2025) Press release of an authority
- CFTC Docket No. 25-07, In the Matter of [Händler] and Flatiron Futures Traders, LLC, Order Instituting Proceedings (09.09.2025) Decision of an authority
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 €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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6 Jan 2025 Gemini Trust Company, LLCGemini Trust: 5 million USD over misleading statements to the CFTC €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 a company tells the supervisor to assess a product must be complete and reliable; statements made by its representatives are attributed to it.
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.
- CFTC Release No. 9031-25: Gemini Trust Ordered to pay $5 Million for Making False or Misleading Statements, Omissions to the CFTC (13.01.2025) Press release of an authority
- U.S. District Court S.D.N.Y., CFTC v. Gemini Trust Company, LLC, No. 22-cv-04563, Consent Order (so ordered 06.01.2025) Court decision
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 €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 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 €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 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 €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 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 €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.
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.
- U.S. Commodity Futures Trading Commission (CFTC), Veröffentlichung der Behörde (Entscheidung 2024) Decision of an authority
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 €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.
Reportable sales must go into regulatory reports straight away, especially large, market-moving transactions.
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.
- U.S. Commodity Futures Trading Commission (CFTC), Veröffentlichung der Behörde (Entscheidung 2024) Decision of an authority
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 €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.
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, Pressemitteilungen (Übersicht) (Entscheidung 2024) Press release of an authority
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 €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.
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.
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.
- U.S. Commodity Futures Trading Commission (CFTC), Veröffentlichung der Behörde (Entscheidung 2024) Decision of an authority
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 €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, Pressemitteilungen (Übersicht) (Entscheidung 2024) Press release of an authority
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 €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.
Intra-group transfers through the exchange are wash sales if both sides are not independently controlled; other routes are needed for them.
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.
- U.S. Commodity Futures Trading Commission (CFTC), Veröffentlichung der Behörde (Entscheidung 2024) Decision of an authority
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 €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.
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.
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.
- U.S. Commodity Futures Trading Commission (CFTC), Veröffentlichung der Behörde (Entscheidung 2024) Decision of an authority
Checked against the official source on 8 Oct 2026 · Company name anonymised since 17 Jun 2026 · Direct link