Who was sanctioned, and for what?

Because revenue had been overstated at the company and its consolidated subsidiary or subsidiaries, the quarterly report for the third quarter of 2023 (filed on 10 November 2023) showed a consolidated loss of 1,382,861 thousand JPY instead of 1,662,516 thousand JPY; the registration statement for a share issue relied on this report, and on 26 February 2024 3,784,200 shares were issued for 3,999,899,400 JPY. After the company admitted the facts and the amount, an administrative monetary penalty (kachōkin) of 91,495,000 JPY was imposed: 1,500,000 JPY for the quarterly report and 89,995,000 JPY for the registration statement.

Authority / court

Financial Services Agency (FSA, 金融庁) auf Empfehlung der Securities and Exchange Surveillance Commission (SESC, 証券取引等監視委員会)

Area of law

Capital markets and financial supervision · Disclosure and reporting obligations

Legal basis

Financial Instruments and Exchange Act (FIEA, 金融商品取引法) Art. 172-4 Abs. 2 a. F., Art. 172-2 Abs. 1 Nr. 1, Art. 185-7 Abs. 1 und 14

Action

Fine

Status of proceedings

unknown

Sector

Energy and utilities

Mitigating circumstances

Both partial amounts were halved because the company had filed a report for a reduction before the inspection began (Art. 185-7(14) FIEA).

Published

17 Sep 2026

Original amount 91,495,000 JPY, converted at the ECB reference rate of 16 Sep 2026.

Checked against the official source on 4 Oct 2026 · Direct link

As a so-called fund hotel, the company had its funds managed by other firms, but examined these delegation agreements only insufficiently, did not take the related decisions properly and did not monitor the funds’ returns in relation to risk closely enough. The Swedish financial supervisory authority Finansinspektionen (FI) issued a remark and imposed 2 million SEK; no damage to investors was established.

Authority / court

Finansinspektionen (FI)

Area of law

Capital markets and financial supervision · Organisational requirements

Legal basis

Schwedisches Fondsrecht – Regeln zur Delegation der Fondsverwaltung und deren Überwachung

Action

Fine

Status of proceedings

unknown

Sector

Financial services and insurance

Mitigating circumstances

No established damage to investors; remedial measures already taken during the investigation.

Published

16 Sep 2026

Original amount 2,000,000 SEK, converted at the ECB reference rate of 16 Sep 2026.

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

The BCB (central bank) sanctions committee COPAS imposed a fine of BRL 2,576,000.00 on Lebes Financeira S.A. – Sociedade de Crédito, Financiamento e Investimento because from January 2022 to March 2023 it engaged in prohibited credit transactions with a related company: its banking correspondent retained collected loan instalments, and the arrears reached BRL 147m at the end of November 2022, or 207.66% of adjusted equity against a limit of 10%. In addition there was a BRL 20m loan routed through a third company. The decision is not final.

Authority / court

Banco Central do Brasil (Comitê de Decisão de Processo Administrativo Sancionador – COPAS)

Area of law

Capital markets and financial supervision · Organisational requirements

Legal basis

Lei 13.506/2017, Art. 3 II; Lei 4.595/1964, Art. 34 § 3 V d und § 4 I; Resolução CMN 4.693/2018, Arts. 5, 6 und 7 II

Action

Fine

Status of proceedings

under appeal

Sector

Financial services and insurance

Liability of senior managers

Measures against individuals are not set out here.

Original amount 2,576,000 BRL, converted at the ECB reference rate of 12 Aug 2026.

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

The KNF imposed five fines totalling PLN 47,500,000 on PKO BP in connection with structured deposits: PLN 26m for failing to inform clients of existing conflicts of interest, PLN 8m each for not analysing costs and charges and for an imprecise definition of the risk category and target market, PLN 4m for selling without checking target-market suitability and PLN 1.5m for misleading sales material on two products. The decision is not final.

Authority / court

Komisja Nadzoru Finansowego (KNF)

Area of law

Capital markets and financial supervision · Organisational requirements

Legal basis

Art. 88c Abs. 1 und 2, Art. 88m Abs. 5 und 9 Prawo bankowe i. V. m. Verordnung des Finanzministers vom 21.01.2019 über Dienstleistungen der Banken bei strukturierten Einlagen

Action

Fine

Status of proceedings

unknown

Sector

Financial services and insurance

Original amount 47,500,000 PLN, converted at the ECB reference rate of 5 Aug 2026.

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

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.

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

The SFC publicly reprimanded China Industrial Securities International Asset Management (CISIAM) and fined it HKD 6.8 million because, between August 2019 and September 2020, the manager of a private fund set up for the insurer Tahoe Life acquired complex structures with notes linked to bonds of a related company at the request of the insurer's chief investment officer, without identifying and properly examining the red flags. CISIAM also failed to observe the fund's investment restrictions and objectives and did not manage its risks effectively. In setting the penalty, the SFC also took into account management fees of around HKD 1.9 million received from the fund.

Authority / court

Securities and Futures Commission (SFC), Hongkong

Area of law

Capital markets and financial supervision · Organisational requirements

Legal basis

Section 194 Securities and Futures Ordinance (Cap. 571); General Principle 2 Code of Conduct; Paragraphen 1.2(d), 3.1 und 3.11.1 Fund Manager Code of Conduct; Abschnitt VIII Management, Supervision and Internal Control Guidelines

Action

Fine

Status of proceedings

unknown

Sector

Financial services and insurance

Repeat case

no

Mitigating circumstances

Remedial measures (new policies on risk management and dubious investment arrangements, compliance training), cooperation with the SFC and an otherwise clean disciplinary record.

Published

27 Jul 2026

Original amount 6,800,000 HKD, converted at the ECB reference rate of 27 Jul 2026.

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

Bright Smart Securities International (H.K.) was publicly reprimanded and fined 2,800,000 HKD because between November 2023 and September 2025 its controls did not prevent 615 clients from executing 1,021 pairs of wash trades (trades without a change in beneficial ownership) in 736 shares and warrants. Monitoring was mostly after the event and manual, and several wash trades by one client on the same day counted as a single occurrence. Similar deficiencies had been identified and raised repeatedly before but were not fully remedied in any instance.

Authority / court

Securities and Futures Commission (SFC)

Area of law

Capital markets and financial supervision · Market abuse and insider dealing

Legal basis

s. 194 SFO (Cap. 571); Code of Conduct GP 2, para. 4.3

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Mitigating circumstances

Enhanced systems and a commitment to an independent effectiveness review, cooperation.

Published

27 Jul 2026

Original amount 2,800,000 HKD, converted at the ECB reference rate of 27 Jul 2026.

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

The financial services provider had not made sure that its clients were protected against losses from theft, fraud or other dishonest acts by its employees; one individual's misconduct caused clients substantial losses. The company was directed to introduce, within two months, a policy protecting against such risks. The amount and the facts have not been confirmed against the primary source.

Authority / court

Financial Sector Conduct Authority (FSCA)

Area of law

Capital markets and financial supervision · Organisational requirements

Legal basis

Sections 2 und 11 General Code of Conduct for Authorised Financial Services Providers and Representatives (2003); Section 13(3)(a) Financial Advisory and Intermediary Services Act 37 of 2002; Section 42(1) Determination of Fit and Proper Requirements for Financial Services Providers (2017)

Action

Fine

Status of proceedings

unknown

Sector

Financial services and insurance

Mitigating circumstances

According to the authority's update of 22 July 2026, the company had itself discovered and reported the contraventions, which occurred in 2021.

Liability of senior managers

Measures against individuals are not set out here.

Published

17 Jul 2026

Checked against the official source on 4 Oct 2026 · Direct link

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.

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

The PRA fined HDI Global SE, an insurer headquartered in Hanover that operates in the UK through a branch, 4,165,000 GBP. Between August 2021 and August 2024 the firm repeatedly submitted incorrect data on liabilities protected by the FSCS and on the FSCS levy tariff, including in supposedly corrected submissions; it lacked written procedures, clear accountability and internal oversight, and before summer 2023 it did not consult the PRA's rules and guidance.

Authority / court

Prudential Regulation Authority (PRA), Bank of England

Area of law

Capital markets and financial supervision · Disclosure and reporting obligations

Legal basis

PRA Fundamental Rules 2 und 6; s. 206 FSMA 2000

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Culpability

negligent

Mitigating circumstances

Detailed account under the Early Account Scheme, settlement with a 30% discount (otherwise 5,950,000 GBP), corrected historical data and additional FSCS levies paid; in the PRA's view the breaches were neither deliberate nor reckless.

Published

20 Jul 2026

Original amount 4,165,000 GBP, converted at the ECB reference rate of 16 Jul 2026.

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

Germany's Federal Financial Supervisory Authority (Bundesanstalt für Finanzdienstleistungsaufsicht, BaFin) imposed a fine of 240,000 EUR on the software company because it had not disclosed the information about a cyberattack it had suffered as inside information without delay. The fine notice is final.

Authority / court

Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)

Area of law

Capital markets and financial supervision · Disclosure and reporting obligations

Legal basis

Art. 17 Abs. 1 UAbs. 1 MAR (EU) Nr. 596/2014

Action

Fine

Status of proceedings

final

Sector

Telecoms, IT and software

Published

20 Jul 2026

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

The Baltimore-based US asset manager had not submitted voting rights notifications to the issuer and BaFin in time; the deadline is four trading days after reaching a notifiable threshold. BaFin imposed a fine of 187,500 EUR; the notice is final.

Authority / court

Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)

Area of law

Capital markets and financial supervision · Disclosure and reporting obligations

Legal basis

§ 33 Abs. 1 Satz 1 WpHG

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Published

22 Jul 2026

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

The Federal Court of Australia, on application by the Australian Securities and Investments Commission (ASIC, Australia's corporate, markets and financial services regulator), imposed a penalty of 20.5 million AUD on the exchange operator because a market announcement of 10 February 2022 stated that the project to replace its CHESS clearing and settlement system was progressing well. About six weeks later ASX announced a likely delay and paused the project in November 2022; in June 2026 it admitted contraventions of ss 12DA and 12DB of the ASIC Act.

Authority / court

Federal Court of Australia (auf Antrag der Australian Securities and Investments Commission, ASIC)

Area of law

Capital markets and financial supervision · Disclosure and reporting obligations

Legal basis

Australian Securities and Investments Commission Act 2001 (Cth) ss 12DA, 12DB(1)(a) und (e)

Action

Fine

Status of proceedings

unknown

Sector

Financial services and insurance

Published

3 Jul 2026

Original amount 20,500,000 AUD, converted at the ECB reference rate of 3 Jul 2026.

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

The credit rating agency did not submit up-to-date rating information to the European Securities and Markets Authority (ESMA), did not provide complete historical performance data to the central repository and lacked adequate procedures and internal control mechanisms. ESMA found negligent infringements and imposed fines totalling 2,145,000 EUR.

Authority / court

Europäische Wertpapier- und Marktaufsichtsbehörde (ESMA)

Area of law

Capital markets and financial supervision · Organisational requirements

Legal basis

Verordnung (EG) Nr. 1060/2009 (CRA-Verordnung), Art. 24, 36a, Anhang III

Action

Fine

Status of proceedings

unknown

Sector

Financial services and insurance

Culpability

negligent

Repeat case

yes

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

Because Paysera did not comply with the order to submit its 2024 annual financial statements by 30 September 2025, the Lietuvos bankas (Bank of Lithuania, financial supervisor) first imposed 20,000 EUR in November 2025 and then a daily fine of 1,000 EUR (rising to 2,000 and 3,000 EUR respectively). As the infringement was only remedied after 6 May 2026, the daily fine added up to 362,000 EUR. Source: archived copy of the press release.

Authority / court

Lietuvos bankas (Litauische Zentralbank, Finanzaufsicht)

Area of law

Capital markets and financial supervision · Disclosure and reporting obligations

Legal basis

Aufsichtsrechtliche Anordnung und Berichtspflichten nach litauischem E-Geld-Recht

Action

Fine

Status of proceedings

unknown

Sector

Financial services and insurance

Repeat case

yes

Published

30 Jun 2026

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

The FCA barred the debt advice firm Curtis Faraday Limited with immediate effect from accepting new customers or referrals for debt, insolvency and IVA-related activities and required it to refer existing customers to other advice providers. Based on file reviews and call recordings, the FCA saw indications that customers' financial information was distorted during the advice process, that the business model, with close links to insolvency service providers, created conflicts of interest and a bias towards commission-generating solutions, that staff circumvented controls and that the firm repeatedly gave the FCA incomplete or inconsistent information.

Authority / court

Financial Conduct Authority (FCA)

Area of law

Capital markets and financial supervision · Organisational requirements

Legal basis

s. 55L(3)(a) FSMA 2000; Threshold Conditions nach Schedule 6 FSMA (paras. 2C, 2D, 2E und 2F)

Action

Order

Status of proceedings

unknown

Sector

Financial services and insurance

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

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.

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

In stock option plans for employees of client companies (2018–2023), the bank did not fully inform the beneficiaries about costs, had initially not recorded the conflicts of interest in this business and assessed clients’ knowledge only with a yes/no question. The Autorité des services et marchés financiers (Belgian Financial Services and Markets Authority, FSMA) accepted a settlement of 1 million EUR with publication by name and commitments on cost information.

Authority / court

Autorité des services et marchés financiers (FSMA)

Area of law

Capital markets and financial supervision · Organisational requirements

Legal basis

Loi du 2 août 2002; Wohlverhaltensregeln (Loyalität, Kostentransparenz, bestmögliche Ausführung, Interessenkonflikte, Kundenkenntnis)

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Repeat case

yes

Mitigating circumstances

Remediation of all deficiencies (appropriateness test, conflicts policy, cost disclosure, waiver of CVA/KVA discounts).

Published

26 Jun 2026

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

The Sanctions Committee of the FSMA (Belgian Financial Services and Markets Authority) found that the shipping company Exmar NV, listed on Euronext Brussels, had not disclosed as soon as possible inside information it held on 19 May and 18 June 2020; the information related to a customer's missing payments for the charter of a floating LNG facility. It imposed a fine of 350,000 EUR and ordered publication by name for one year. Exmar has lodged an appeal with the Market Court.

Authority / court

Autoriteit voor Financiële Diensten en Markten / Autorité des services et marchés financiers (FSMA) – Sanctiecommissie

Area of law

Capital markets and financial supervision · Disclosure and reporting obligations

Legal basis

Art. 17 Verordnung (EU) Nr. 596/2014 (MAR); Art. 36 § 2 und Art. 72 § 3 Gesetz vom 2. August 2002 über die Aufsicht über den Finanzsektor

Action

Fine

Status of proceedings

under appeal

Sector

Transport, logistics and shipping

Checked against the official source on 2 Oct 2026 · Direct link

According to the AMF (Autorité des marchés financiers, French financial markets authority) Enforcement Committee, the online broker Bourse Direct did not properly submit its transaction reports under Art. 26 MiFIR between January 2021 and November 2023 and did not maintain an adequate system to detect and report suspicious orders and transactions under Art. 16(2) MAR. The company received EUR 800,000. The amount covers only the sanction imposed on the company.

Authority / court

Autorité des marchés financiers (AMF), Commission des sanctions

Area of law

Capital markets and financial supervision · Disclosure and reporting obligations

Legal basis

Art. 26 Verordnung (EU) Nr. 600/2014 (MiFIR); Art. 15 Delegierte Verordnung (EU) 2017/590; Art. 16 Abs. 2 Verordnung (EU) Nr. 596/2014 (MAR); Art. 2, 3 Delegierte Verordnung (EU) 2016/957

Action

Fine

Status of proceedings

unknown

Sector

Financial services and insurance

Employees

50 to 249

Published

25 Jun 2026

Checked against the official source on 2 Oct 2026 · Direct link