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.

59cases from 19 jurisdictions
€507.3mTotal of monetary amounts (56 cases with an amount)
€166.7mLargest single case: Becton, Dickinson and Company (BD)
€394,880Median 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 20231€280,000
Q1 20243€2.4m
Q2 20240—
Q3 20243€44.8m
Q4 20248€240.1m
Q1 20255€130.2m
Q2 20252€3.47m
Q3 20256€1.03m
Q4 20256€618,385
Q1 20268€52.5m
Q2 202612€7.36m
Q3 20264€752,878

59 cases

16 Sep 2026 AIFM Capital ABAIFM Capital: 2 million SEK for inadequate selection and oversight of fund managers SwedenOrganisational requirements €177,187

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.

What organisations can take from it

Outsourcing tasks does not outsource responsibility: document the selection of service providers, the decisions taken and ongoing oversight.

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

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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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16 Jul 2026 TeamViewer SETeamViewer: cyberattack not disclosed as inside information without delay GermanyDisclosure and reporting obligations €240,000

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.

What organisations can take from it

Put serious IT security incidents immediately before the ad hoc disclosure committee as well – the incident response process must take capital market disclosure into account.

Relevance to training and awareness

Recognising security incidents as potential inside information and reporting them to the ad hoc disclosure committee

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

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10 Jul 2026 Brown Capital Management LLCBrown Capital Management: voting rights notifications not submitted on time GermanyDisclosure and reporting obligations €187,500

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.

What organisations can take from it

Anyone investing in German issuers needs automated threshold monitoring with clear responsibility for the four-day deadline.

Relevance to training and awareness

Threshold monitoring and notification deadlines for shareholdings

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

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30 Jun 2026 Moody's Deutschland GmbHESMA fines Moody's Deutschland 2.1 million EUR EU levelOrganisational requirements €2.15m

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.

What organisations can take from it

Reporting obligations to the supervisory authority are data quality issues – without functioning internal controls, they become a risk of fines.

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

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30 Jun 2026 „Paysera LT“, UABPaysera: daily fine for missing annual accounts adds up to 362,000 EUR LithuaniaDisclosure and reporting obligations €362,000

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.

What organisations can take from it

Running daily fines make every delay expensive – supervisory orders need top-management priority.

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

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26 Jun 2026 Banque Degroof Petercam SABanque Degroof Petercam: 1 million EUR settlement over hidden costs in employee stock options BelgiumOrganisational requirements €1m

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.

What organisations can take from it

Full cost transparency and a dedicated conflicts register also apply to ancillary business such as employee stock option plans.

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

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23 Jun 2026 VARTA AGVARTA: late ad hoc announcement and missing half-yearly financial report GermanyDisclosure and reporting obligations €620,000

BaFin imposed fines on the battery manufacturer because it had not disclosed inside information without delay and had not published the half-yearly financial report for the 2024 financial year.

What organisations can take from it

Ad hoc assessments and periodic disclosure require fixed responsibilities and deadline controls so that neither inside information nor mandatory reports are left pending.

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; § 115 Abs. 1 Satz 1 WpHG
Action
Fine
Status of proceedings
final
Sector
Manufacturing and mechanical engineering
Published
1 Jul 2026

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

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8 Jun 2026 A. Tsokkos Hotels Public LimitedCyprus: 16,500 EUR against A. Tsokkos Hotels for late annual financial report CyprusDisclosure and reporting obligations €16,500

The listed hotel group did not publish its 2024 annual financial report on time; the Cyprus Securities and Exchange Commission (CySEC) imposed a total of 16,500 EUR. At the same meeting, eleven other issuers were fined between 1,500 and 17,000 EUR for the same reason; a fine of 13,500 EUR had already been imposed on the company under the same law in 2025.

What organisations can take from it

Publication deadlines for financial reports are not negotiable – repeated delays lead to fines and, in extreme cases, to suspension of trading.

Authority / court
Cyprus Securities and Exchange Commission (CySEC)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Sec. 9(1), 37(2)(a) Transparency Requirements (Securities Admitted to Trading on a Regulated Market) Law 2007
Action
Fine
Status of proceedings
unknown
Sector
Other
Repeat case
yes
Published
7 Aug 2026

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

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27 May 2026 Soltec Power Holdings, SASoltec: incorrect 2023 annual figures reported to the market SpainDisclosure and reporting obligations €190,000

The manufacturer of solar tracking systems disseminated its results for 2023 by way of an "Otra Información Relevante" announcement containing inaccurate information. Spain's National Securities Market Commission (CNMV) imposed a fine of 190,000 EUR for a serious infringement; the company waived administrative appeals.

What organisations can take from it

Voluntary market announcements on results are also subject to MAR – figures must be reconciled before publication.

Authority / court
Comisión Nacional del Mercado de Valores (CNMV)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Art. 297.1.e i. V. m. 297.2.d Ley 6/2023; Art. 17 i. V. m. Art. 7 MAR
Action
Fine
Status of proceedings
unknown
Sector
Energy and utilities
Published
3 Aug 2026

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

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25 May 2026 Robomarkets LtdCyprus: Robomarkets pays 100,000 EUR under settlement over CFD sales to retail clients CyprusOrganisational requirements €100,000

For the period June 2023 to June 2024, the Cyprus Securities and Exchange Commission (CySEC) examined the investment firm’s organisational requirements, client information, appropriateness assessment and compliance with the restrictions on marketing CFDs to retail investors. The proceedings were concluded with a settlement of 100,000 EUR, which the company has already paid.

What organisations can take from it

When selling CFDs to retail clients, the appropriateness assessment and product intervention rules are central points of supervisory scrutiny.

Relevance to training and awareness

Appropriateness assessment when selling complex products

Authority / court
Cyprus Securities and Exchange Commission (CySEC)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Art. 22(1), 25(1), 26(3) Gesetz über Wertpapierdienstleistungen 2017; Art. 42 VO (EU) 600/2014; CySEC-Richtlinie DI87-09; Art. 37(4) CySEC-Gesetz
Action
Other
Status of proceedings
final
Sector
Financial services and insurance
Published
24 Aug 2026
Sources

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

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13 May 2026 Oma Säästöpankki OyjOma Säästöpankki: 400,000 EUR over late and incomplete insider lists FinlandMarket abuse and insider dealing €400,000

The bank failed to draw up insider lists in good time for two pieces of inside information (termination of the core banking project with Cognizant in 2021, merger talks with Liedon Säästöpankki in 2022), did not update them and omitted mandatory information. The Finanssivalvonta (Finnish Financial Supervisory Authority, FIN-FSA) imposed a total fine of 400,000 EUR; the decision was not appealed and is final.

What organisations can take from it

Insider lists must be created from the moment inside information exists – a fixed process with designated responsible persons prevents gaps.

Relevance to training and awareness

Insider lists and handling of inside information

Authority / court
Finanssivalvonta (FIN-FSA)
Area of law
Capital markets and financial supervision · Market abuse and insider dealing
Legal basis
Verordnung (EU) Nr. 596/2014 (MAR) Art. 18 Abs. 1, 3 und 4; Durchführungsverordnung (EU) 2016/347
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Measures to prevent recurrence and partial admission/cooperation had a mitigating effect.
Published
15 May 2026

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

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8 May 2026 Stan Bharti und Neil Said (ehem. CEOs der Medivolve Inc.)Medivolve: former CEOs conceal their own share allocation – sanctions running into millions Canada, ONDisclosure and reporting obligations €1.71m

The former CEOs Stan Bharti and Neil Said failed to ensure that Medivolve disclosed that they had received millions of shares in the acquisition of Amino Therapeutics in April 2020; the financial disclosures omitted this related-party transaction. Under the approved settlement: Bharti 785,000 CAD penalty and 915,000 CAD disgorgement, Said 200,000 CAD penalty and 854,000 CAD disgorgement, in each case plus costs.

What organisations can take from it

Transactions in which board members themselves receive shares must be disclosed – and those responsible are personally liable.

Authority / court
Capital Markets Tribunal (Ontario) auf Antrag der Ontario Securities Commission
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Securities Act (Ontario), RSO 1990, c S.5, s. 129.2
Action
Fine
Status of proceedings
final
Liability of senior managers
Stan Bharti (CEO/Director): 785,000 CAD penalty, 915,000 CAD disgorgement, 50,000 CAD costs, permanent officer-and-director bar; Neil Said (CEO): 200,000 CAD penalty, 854,000 CAD disgorgement, 46,000 CAD costs, 5-year officer-and-director bar

Original amount 2,754,000 CAD, converted at the ECB reference rate of 8 May 2026.

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

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5 May 2026 P&V Assurances SCP&V Assurances: 150,000 EUR – distribution via a deregistered insurance intermediary BelgiumOrganisational requirements €150,000

One of the insurer’s intermediaries was removed from the FSMA register in December 2023; owing to a human data entry error in the monitoring tool, P&V only noticed this after more than a month and concluded 34 contracts through him during that time. The Autorité des services et marchés financiers (Belgian Financial Services and Markets Authority, FSMA) accepted a settlement of 150,000 EUR; there had already been a settlement for the same amount in 2020.

What organisations can take from it

Automated register checks are only as good as the underlying data maintenance – critical entries require a four-eyes principle.

Relevance to training and awareness

Care in master data maintenance / register reconciliation

Authority / court
Autorité des services et marchés financiers (FSMA)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Loi du 4 avril 2014 relative aux assurances, Art. 259
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Repeat case
yes
Mitigating circumstances
IT adjustments to prevent recurrence.
Published
5 May 2026

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

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15 Apr 2026 Liquidnet Canada Inc.Liquidnet Canada: confidential order data passed on to unauthorised persons Canada, ONOrganisational requirements €369,572

The operator of alternative trading systems passed on confidential order and trading information from its fixed income and equity platforms to unauthorised employees, lacked adequate safeguards and was initially not forthcoming with the regulator. Sanctions: administrative penalty of 600,000 CAD, 75,000 CAD in costs, a reprimand and an external review.

What organisations can take from it

Technically restrict access rights to confidential client data and review them regularly – and make complete reports to the regulator.

Relevance to training and awareness

Need-to-know principle and protection of confidential trading data

Authority / court
Capital Markets Tribunal (Ontario) auf Antrag der Ontario Securities Commission
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
National Instrument 21-101, s. 5.10(1)-(3); Securities Act (Ontario) ss. 127(1), 127.1
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Cooperation, self-report, no prior record

Original amount 600,000 CAD, converted at the ECB reference rate of 15 Apr 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 Mar 2026 Dinosaur Merchant Bank LimitedDinosaur Merchant Bank: 338,000 GBP – CFD trading without market abuse surveillance United KingdomOrganisational requirements €389,760

After a new order management system was introduced in June 2024, CFD transactions with an underlying value of around 3.05 billion USD were not captured by automated trade surveillance. The bank identified the error in October 2024 but only remedied it in May 2025; the Financial Conduct Authority (FCA) imposed 338,000 GBP after a 30% cooperation discount.

What organisations can take from it

With every system migration, check whether surveillance systems actually capture the new data flows.

Authority / court
Financial Conduct Authority (FCA)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Art. 16 Abs. 2 UK MAR; SYSC 6.1.1R; FCA Principle 3
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Full cooperation (30% discount); CFD business discontinued in May 2025.

Original amount 338,000 GBP, converted at the ECB reference rate of 27 Mar 2026.

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

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25 Mar 2026 Familiam Asset Management OyFamiliam Asset Management: 70,000 EUR for 2,867 unreported securities transactions FinlandDisclosure and reporting obligations €70,000

Between September 2021 and August 2023, the asset manager failed to report a total of 2,867 transactions to the supervisory authority on time and in 2024 also submitted quarterly reports (FINREP) late. The Finanssivalvonta (Finnish Financial Supervisory Authority, FIN-FSA) imposed a total fine of 70,000 EUR; the admission had a mitigating effect.

What organisations can take from it

Reporting obligations require deadline monitoring with a deputy arrangement – especially in small firms without their own reporting department.

Relevance to training and awareness

Regulatory reporting

Authority / court
Finanssivalvonta (FIN-FSA)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
MiFIR (VO (EU) 600/2014) Art. 26 Abs. 1; IFR (VO (EU) 2019/2033) Art. 54 Abs. 1; FIN-FSA-Vorschriften 20/2013 (FINREP)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Admission of the failures / cooperation.
Published
25 Mar 2026

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

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4 Mar 2026 Schaeffler AGSchaeffler: deviation of quarterly figures from market expectations disclosed too late GermanyDisclosure and reporting obligations €180,000

The automotive supplier's business figures for the first quarter of 2024 deviated significantly from market expectations; this inside information was not disclosed without delay by means of an ad hoc announcement. BaFin imposed a fine.

What organisations can take from it

Make a comparison of internal figures with the analyst consensus a fixed part of the quarterly process, so that significant deviations are immediately assessed for ad hoc disclosure obligations.

Relevance to training and awareness

Recognising inside information in deviations from market expectations (controlling/IR)

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
Action
Fine
Status of proceedings
final
Sector
Automotive
Published
26 Mar 2026

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

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3 Mar 2026 John Wood Group PLCJohn Wood Group: incorrect financial results published – almost 13 million GBP United KingdomDisclosure and reporting obligations €14.9m

The energy services company published incorrect results for the 2022 and 2023 financial years and for the first half of 2024; accounting judgements were influenced by the desire to maintain previously reported figures, and systems and controls were inadequate. The UK Financial Conduct Authority (FCA) imposed a fine of 12,993,700 GBP (18,562,500 GBP without the 30 % discount).

What organisations can take from it

Accounting judgements must not be geared to figures already communicated – this is a control failure, not a calculation error.

Authority / court
Financial Conduct Authority (FCA)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Listing Rule 1.3.3R; Listing Principle 1
Action
Fine
Status of proceedings
final
Sector
Energy and utilities
Employees
10,000 or more
Mitigating circumstances
30 % discount for early settlement and acceptance of the findings
Published
4 Mar 2026

Original amount 12,993,700 GBP, converted at the ECB reference rate of 3 Mar 2026.

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

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17 Feb 2026 REGIS-TR S.A.Trade repository REGIS-TR: deficiencies in organisation and data protection – 1.37 million EUR EU levelOrganisational requirements €1.37m

The Luxembourg trade repository lacked adequate compliance procedures and an appropriate organisational structure, failed to identify operational risks and did not adequately protect the confidentiality and integrity of the reported data. ESMA imposed fines totalling 1,374,000 EUR for negligent infringements under EMIR and SFTR; the case is under appeal.

What organisations can take from it

Market infrastructures must manage operational risks and data access as strictly as banks manage their credit risks.

Authority / court
Europäische Wertpapier- und Marktaufsichtsbehörde (ESMA)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Verordnung (EU) Nr. 648/2012 (EMIR), Art. 65, 73, Anhang I; Verordnung (EU) 2015/2365 (SFTR), Art. 9
Action
Fine
Status of proceedings
under appeal
Sector
Financial services and insurance
Culpability
negligent
Repeat case
yes

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 2026 M. van Wettum (indirekter Direktor einer an NX Filtration N.V. beteiligten Gesellschaft)Marking the close at NX Filtration: 625,000 EUR fine for investor NetherlandsMarket abuse and insider dealing €625,000

On the last trading day of 2023, shortly before the market close, the investor had NX Filtration shares bought in order – according to a recorded telephone call – to raise the closing price from 6.30 to 6.70 EUR, which succeeded. The Dutch Authority for the Financial Markets (AFM) classified this as market manipulation ("marking the close") and imposed a fine of 625,000 EUR.

What organisations can take from it

Influencing share prices on balance sheet dates is market manipulation – broker orders with price targets are recorded and analysed.

Relevance to training and awareness

Prohibited price support at year-end (marking the close)

Authority / court
Autoriteit Financiële Markten (AFM)
Area of law
Capital markets and financial supervision · Market abuse and insider dealing
Legal basis
Art. 15 MAR
Action
Fine
Status of proceedings
under appeal
Sector
Manufacturing and mechanical engineering
Culpability
intentional
Published
13 Jul 2026

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

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7 Jan 2026 Richard Adam und Zafar Khan (ehem. Finanzvorstände der Carillion plc, in Liquidation)Carillion: former finance directors personally penalised for misleading announcements United KingdomMarket abuse and insider dealing €429,017

The former finance directors Richard Adam and Zafar Khan acted recklessly and were involved in the construction group's breaches of MAR and the Listing Rules: the financial reporting on the UK construction business was inaccurate, and the board was not informed of serious problems. Fines: 232,800 GBP (Adam) and 138,900 GBP (Khan).

What organisations can take from it

Finance directors are personally liable if they fail to escalate known problems to the board and allow embellished figures to be published.

Authority / court
Financial Conduct Authority (FCA)
Area of law
Capital markets and financial supervision · Market abuse and insider dealing
Legal basis
Art. 15 MAR (Marktmanipulation durch falsche Informationen); Listing Rule 1.3.3R; Listing Principle 1; Premium Listing Principle 2
Action
Fine
Status of proceedings
final
Sector
Construction and real estate
Liability of senior managers
Richard Adam (finance director until 2016): 232,800 GBP; Zafar Khan (finance director 2017): 138,900 GBP

Original amount 371,700 GBP, converted at the ECB reference rate of 7 Jan 2026.

Sources

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19 Dec 2025 Russel Gerrity (Berater; Handel in Chariot Oil & Gas und Eco (Atlantic) Oil and Gas)Oil and gas consultant trades on knowledge of drilling results – insider dealing United KingdomMarket abuse and insider dealing €353,702

Between 2018 and 2022, a consultant with access to confidential drilling results bought shares in Chariot Oil & Gas and Eco (Atlantic) Oil and Gas ahead of positive announcements and on one occasion sold ahead of a negative one. The FCA imposed 309,843 GBP (128,765 GBP disgorgement, 181,078 GBP penalty); the investigation was triggered by suspicious transaction and order reports (STORs) from a financial firm.

What organisations can take from it

Put external consultants with access to project or exploration data on the insider list and instruct them on trading bans.

Relevance to training and awareness

Insider dealing ban for external consultants with project access

Authority / court
Financial Conduct Authority (FCA)
Area of law
Capital markets and financial supervision · Market abuse and insider dealing
Legal basis
Art. 14(a) UK MAR
Action
Fine
Status of proceedings
final
Sector
Energy and utilities
Culpability
intentional
Mitigating circumstances
30 % discount for settlement at an early stage of the proceedings
Published
16 Jan 2026

Original amount 309,843 GBP, converted at the ECB reference rate of 19 Dec 2025.

Sources

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10 Dec 2025 Invest in OÜLender Invest in OÜ pays 16,000 EUR for failing to submit annual accounts EstoniaDisclosure and reporting obligations €16,000

The lender did not submit its 2024 annual report, together with the audit report, the resolution on the appropriation of profits and the minutes of the shareholders’ meeting, to the financial supervisory authority on time. In misdemeanour proceedings, the Finantsinspektsioon (Estonian Financial Supervision Authority) imposed a fine of 16,000 EUR; the maximum is 1 million EUR or 10% of annual turnover. Date = publication.

What organisations can take from it

Even small supervised lenders need a reliable deadline calendar for mandatory supervisory reports.

Authority / court
Finantsinspektsioon (Estnische Finanzaufsicht)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
§ 56 Abs. 3, § 96 Abs. 2 KAVS (Gesetz über Kreditgeber und -vermittler)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
10 Dec 2025

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24 Oct 2025 Jessica Tam (Handel in Optionen der Score Media and Gaming Inc.)Tip from the VP Finance: insider trading ahead of Score Media takeover Canada, ONMarket abuse and insider dealing €73,683

In 2021, Jessica Tam bought call options on the instructions of an acquaintance, the VP Finance of Score Media and Gaming, ahead of the announcement of the takeover by Penn National Gaming; the profit was around 311,000 USD, and the split was arranged via WhatsApp using code words and settled in cash. Under the settlement: 120,000 CAD disgorgement and a two-year trading ban.

What organisations can take from it

Insider training must make clear that even trading on a tip from one's private circle is prohibited – and that code words and cash payments do not prevent detection.

Relevance to training and awareness

Passing on inside information (tipping) in one's private circle

Authority / court
Capital Markets Tribunal (Ontario) auf Antrag der Ontario Securities Commission
Area of law
Capital markets and financial supervision · Market abuse and insider dealing
Legal basis
Securities Act (Ontario), s. 76(1) (Insiderhandel); Sanktionen nach s. 127(1)
Action
Disgorgement of profits
Status of proceedings
final
Sector
Media and online platforms
Culpability
intentional
Mitigating circumstances
Admission, implication of other participants and undertaking to testify as a witness
Published
4 Nov 2025

Original amount 120,000 CAD, converted at the ECB reference rate of 24 Oct 2025.

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21 Oct 2025 Taxshelter.be SATaxshelter.be: 75,000 EUR for missing prospectus supplement on guarantee risks BelgiumDisclosure and reporting obligations €75,000

After the tax authority had refused the tax shelter certificates for a financed show and the insurer left cover open, the provider failed to inform investors of this material risk in good time by means of a prospectus supplement. The Autorité des services et marchés financiers (Belgian Financial Services and Markets Authority, FSMA) accepted a settlement of 75,000 EUR with publication by name.

What organisations can take from it

New material risks for investors trigger an immediate obligation to publish a supplement – not only in the next annual prospectus.

Authority / court
Autorité des services et marchés financiers (FSMA)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Verordnung (EU) 2017/1129 Art. 23; Loi du 11 juillet 2018 (Loi Prospectus)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
21 Oct 2025

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13 Oct 2025 Wonderinterest Trading LtdCyprus: 100,000 EUR against Wonderinterest Trading over misleading client information CyprusOrganisational requirements €100,000

For 2022 to 2024, the Cyprus Securities and Exchange Commission (CySEC) found that the investment firm had no adequate compliance procedures, did not define target markets for its financial instruments, did not act in the best interests of clients and did not inform clients in a fair, clear and not misleading manner. It imposed fines of 50,000, 30,000 and 20,000 EUR; a judicial review of the decision has been recorded.

What organisations can take from it

Advertising statements by financial service providers must present risks in a balanced way – marketing belongs in the compliance approval process.

Relevance to training and awareness

Fair and not misleading marketing communications

Authority / court
Cyprus Securities and Exchange Commission (CySEC)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Sec. 17(2), 17(3)(c), 22(1), 25(1), 25(3)(a) Gesetz über Wertpapierdienstleistungen 2017; Art. 22, 44 Delegierte VO (EU) 2017/565
Action
Fine
Status of proceedings
under appeal
Sector
Financial services and insurance
Published
17 Dec 2025

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13 Oct 2025 Finamore S.A.Finamore: licence of insurance broker withdrawn over serious deficiencies LuxembourgOrganisational requirements Other

The Commissariat aux Assurances (Luxembourg insurance supervisory authority, CAA) withdrew the broking firm’s licence (effective from 1 December 2025), among other things for using unregistered intermediaries, lacking internal expertise, insufficiently protected confidential data, economically unexplained payment flows with affiliated companies, incomplete or false information provided to the supervisory authority and deficient customer information.

What organisations can take from it

False information to the supervisory authority and unregistered distribution partners can cost the business its existence – not just a fine.

Authority / court
Commissariat aux Assurances (CAA)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Loi modifiée du 7 décembre 2015 sur le secteur des assurances, Art. 303 Abs. 3 lit. c
Action
Other
Status of proceedings
unknown
Sector
Financial services and insurance
Published
29 May 2026

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16 Sep 2025 Go West Invest SAGo West Invest: 10,000 EUR for outdated information note in tax shelter offering BelgiumDisclosure and reporting obligations €10,000

From June 2021 to October 2024, the company, which raises tax shelter funds through public offerings, kept a public offering on its website with an information note from 2020 without publishing an updated note and filing it with the Autorité des services et marchés financiers (Belgian Financial Services and Markets Authority, FSMA); several dozen investors with an investment volume of under 5 million EUR were affected. The FSMA accepted a settlement of 10,000 EUR.

What organisations can take from it

Investor information has an expiry date – a deadline calendar for mandatory documents prevents infringements.

Authority / court
Autorité des services et marchés financiers (FSMA)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Loi du 11 juillet 2018 (Loi Prospectus), Art. 10, 11
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
16 Sep 2025

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5 Sep 2025 „Paysera LT“, UABPaysera took over e-money institution Contis without approval – 400,000 EUR LithuaniaOrganisational requirements €400,000

Paysera acquired 100% of the shares in UAB ‘Finansinės paslaugos „Contis“’ before the assessment period had expired and without a non-objection from the supervisory authority; in April 2025, the Lietuvos bankas (Bank of Lithuania, financial supervisor) objected to the acquisition owing to a lack of documents on reputation, financial soundness and money laundering risks. In addition, the annual financial statements and other reports were not approved and submitted on time. Fine of 400,000 EUR and obligation to remedy by 30 September 2025. Source: archived copy of the press release.

What organisations can take from it

Complete acquisitions of holdings in supervised institutions only after approval – otherwise voting rights are suspended and fines loom.

Authority / court
Lietuvos bankas (Litauische Zentralbank, Finanzaufsicht)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Elektroninių pinigų ir elektroninių pinigų įstaigų įstatymas (Inhaberkontrolle, Berichtspflichten)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
5 Sep 2025

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1 Sep 2025 Blacktower Financial Management (Cyprus) LtdCyprus: Blacktower Financial Management pays 70,000 EUR over conflicts of interest CyprusOrganisational requirements €70,000

For the period November 2020 to May 2025, the Cyprus Securities and Exchange Commission (CySEC) investigated the investment firm’s handling of conflicts of interest and its general conduct of business and information obligations towards clients. The proceedings ended with a settlement of 70,000 EUR, which the company has paid.

What organisations can take from it

Conflicts of interest must be identified, documented and managed vis-à-vis clients – adviser training is the basis for this.

Relevance to training and awareness

Recognising conflicts of interest in investment advice

Authority / court
Cyprus Securities and Exchange Commission (CySEC)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Art. 24(1), 25(1) Gesetz über Wertpapierdienstleistungen 2017; Art. 37(4) CySEC-Gesetz
Action
Other
Status of proceedings
final
Sector
Financial services and insurance
Published
17 Nov 2025

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23 Jul 2025 Condor Courtiers & Conseillers S.à r.l.Condor Courtiers & Conseillers: licence withdrawn for using unlicensed introducers LuxembourgOrganisational requirements Other

Following an on-site inspection in 2024, the Commissariat aux Assurances (Luxembourg insurance supervisory authority, CAA) withdrew the broker’s licence (effective 15 September 2025): there was no effective management by approved managers, unlicensed ‘introducers’ were de facto selling insurance, and the broker’s licence, together with its sub-intermediary network, was improperly made available to third parties.

What organisations can take from it

A distribution licence is not transferable – anyone who ‘rents it out’ to third parties or lets introducers sell risks having it withdrawn.

Authority / court
Commissariat aux Assurances (CAA)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Loi modifiée du 7 décembre 2015 sur le secteur des assurances, Art. 273, 274, 283, 286, 303
Action
Other
Status of proceedings
unknown
Sector
Financial services and insurance
Published
16 Sep 2025

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9 Jul 2025 Share buyback disclosed too late: BVwG reduces FMA penalty against real estate company AustriaDisclosure and reporting obligations €300,000

On Saturday, 17 December 2022, the management board of a listed real estate company (anonymised in the judgment) approved by email a new share buyback programme including its volume, period and price, but only published it after a formal resolution on Monday, 19 December 2022. Austria's Financial Market Authority (FMA) imposed a penalty of 375,000 EUR; the Federal Administrative Court (Bundesverwaltungsgericht, BVwG) upheld the breach of the ad hoc disclosure obligation but reduced the penalty to 300,000 EUR.

What organisations can take from it

A final decision by a corporate body triggers the ad hoc disclosure obligation immediately – weekends and outstanding contractual details do not postpone it.

Relevance to training and awareness

Ad hoc disclosure obligation for decisions of corporate bodies, including at weekends

Authority / court
Bundesverwaltungsgericht (Beschwerde gegen Straferkenntnis der Finanzmarktaufsicht FMA)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Art. 17 Abs. 1 MAR i. V. m. § 156 Abs. 3 Z 2, Abs. 4 BörseG 2018
Action
Fine
Status of proceedings
reduced
Sector
Construction and real estate
Culpability
negligent

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8 Jul 2025 Barents Reinsurance S.A.Barents Reinsurance: maximum fine of 250,000 EUR over governance deficiencies LuxembourgOrganisational requirements €250,000

The reinsurer breached the principle of specialisation in reinsurance business, its approved manager was not effectively present on site and had insufficient powers, the governance system including oversight of outsourced functions was inadequate, and orders from a 2019 inspection had not been implemented or only partially. The Commissariat aux Assurances (Luxembourg insurance supervisory authority, CAA) imposed the statutory maximum of 250,000 EUR; the company cooperated.

What organisations can take from it

On-site substance is a supervisory requirement: management, powers and oversight of outsourced functions must genuinely be located in the home country.

Authority / court
Commissariat aux Assurances (CAA)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Loi modifiée du 7 décembre 2015 sur le secteur des assurances, Art. 49, 71, 81, 274, 303
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
Cooperation with the CAA during and after the inspection.
Published
8 Aug 2025

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10 Jun 2025 SMCP SA; European TopSoho S.à r.l.; Dynamic Treasure GroupSMCP: threshold notifications missed, misleading announcement, inside information not protected FranceMarket abuse and insider dealing €1.72m

In connection with the change of control at the fashion group SMCP in 2021/22, the major shareholder European TopSoho (ETS) and Dynamic Treasure Group failed to make threshold notifications; ETS also disseminated a misleading press release. SMCP itself failed to maintain the confidentiality of inside information. Sanctions imposed by the Enforcement Committee of France's financial markets authority (Autorité des marchés financiers, AMF): Chenran Qiu 1 million EUR, ETS 400,000 EUR, DTG 300,000 EUR, SMCP 20,000 EUR.

What organisations can take from it

Issuers must effectively shield inside information even when the conflict originates with the major shareholder.

Relevance to training and awareness

Ensuring the confidentiality of inside information

Authority / court
Autorité des marchés financiers (AMF), Commission des sanctions
Area of law
Capital markets and financial supervision · Market abuse and insider dealing
Legal basis
Art. L. 233-7 Code de commerce; Art. 223-14 RG AMF; Art. 12 Abs. 1 lit. c MAR; Art. 2 Abs. 1 DVO (EU) 2016/1055
Action
Fine
Status of proceedings
under appeal
Sector
Retail and e-commerce
Liability of senior managers
Chenran Qiu: 1,000,000 EUR (ETS's infringements attributed to her)
Sources

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14 May 2025 SAP SESAP: failure to publish notice on the 2022 annual financial report GermanyDisclosure and reporting obligations €1.75m

SAP had not published an announcement stating from when and at which internet address the 2022 annual financial report was publicly available in addition to the company register (Hinweisbekanntmachung). BaFin imposed a fine of 1.75 million EUR; the notice is final.

What organisations can take from it

Even seemingly formal disclosure steps such as the notice announcement need a fixed place in the financial calendar – the range of fines extends up to five per cent of total turnover.

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
§ 114 Abs. 1 Satz 2 WpHG
Action
Fine
Status of proceedings
final
Sector
Telecoms, IT and software
Published
27 May 2025

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31 Mar 2025 FXNET LimitedCyprus: FXNET pays 225,000 EUR under settlement over organisational and CFD breaches CyprusOrganisational requirements €225,000

The investigation covering 2021 to 2022 concerned compliance organisation, product governance, record-keeping obligations, safeguarding of client funds, client information, suitability and appropriateness assessments and the CFD restrictions for retail investors. Following board resolutions of 17 and 31 March 2025, the Cyprus Securities and Exchange Commission (CySEC) concluded a settlement of 225,000 EUR, which has been paid.

What organisations can take from it

Safeguarding client funds and keeping proper records are basic duties of every investment firm – gaps quickly add up in a settlement.

Authority / court
Cyprus Securities and Exchange Commission (CySEC)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Art. 17, 22(1), 25, 26(3)(a) Gesetz über Wertpapierdienstleistungen 2017; Art. 42 VO (EU) 600/2014; Art. 37(4) CySEC-Gesetz
Action
Other
Status of proceedings
final
Sector
Financial services and insurance
Published
11 Nov 2025

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20 Jan 2025 Pharnext SAPharnext: FDA setbacks disclosed late and glossed over FranceDisclosure and reporting obligations €800,000

The biotech company did not disclose as soon as possible the FDA's request for an additional study on PXT-3003 and the subsequent rejection of an SPA application, and disseminated misleading communications to shareholders. Sanctions: Pharnext 500,000 EUR, former CEO Daniel Cohen 200,000 EUR, former CEO David Horn Solomon 100,000 EUR.

What organisations can take from it

Negative feedback from regulatory authorities is regularly inside information and must not be given a positive spin in letters to shareholders.

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. 17 MAR; Art. 12 Abs. 1 lit. c und Art. 15 MAR
Action
Fine
Status of proceedings
under appeal
Sector
Chemicals and pharmaceuticals
Liability of senior managers
Daniel Cohen (co-founder, directeur général until April 2020): 200,000 EUR; David Horn Solomon (directeur général from April 2020): 100,000 EUR
Sources

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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.

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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.

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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.

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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.

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12 Dec 2024 Leonteq AG (Finanzgruppe Leonteq)Leonteq: distribution via unregulated partners – confiscation of 9.3 million CHF in profits SwitzerlandOrganisational requirements €9.98m

The Swiss Financial Market Supervisory Authority (FINMA) found serious breaches of risk management obligations and of the requirement to guarantee irreproachable business conduct: the financial group monitored its distribution chain inadequately and in some cases worked with dubious, unregulated distributors that sold products in countries not intended for them without authorisation. FINMA ordered governance requirements, the termination of these relationships, the appointment of an audit agent and the confiscation of 9.3 million CHF in profits; the ruling was not yet final at the time of publication.

What organisations can take from it

Anyone who distributes via third parties is liable for their regulatory status – sales partners require due diligence just like customers.

Authority / court
Eidgenössische Finanzmarktaufsicht (FINMA)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Finanzmarktaufsichtsgesetz (FINMAG)
Action
Disgorgement of profits
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
Good cooperation in the proceedings; Leonteq had already strengthened compliance and distribution controls of its own accord and terminated relationships with suspicious distributors

Original amount 9,300,000 CHF, converted at the ECB reference rate of 12 Dec 2024.

Sources

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26 Nov 2024 Macquarie Bank Limited, London BranchMacquarie Bank London: 13 million GBP – trader concealed over 400 fictitious trades United KingdomOrganisational requirements €15.6m

From June 2020 to February 2022, a trader on the metals and commodities desk was able to book over 400 fictitious trades and circumvent three key internal controls in order to conceal losses; the bank was partly aware of the weaknesses but did not remedy them in time. Unwinding the positions cost around 57.8 million USD; the Financial Conduct Authority (FCA) imposed 13 million GBP on the bank and banned the trader Travis Klein.

What organisations can take from it

Close known control weaknesses in trading with a deadline and a responsible person – otherwise a lone perpetrator becomes an organisational failure.

Relevance to training and awareness

Recognising and reporting circumvention of controls in trading

Authority / court
Financial Conduct Authority (FCA)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
FCA Principles for Businesses, Principle 3 (Systeme und Kontrollen); s. 206 Financial Services and Markets Act 2000
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Liability of senior managers
Prohibition order imposed on the trader; no fine imposed on him on grounds of serious financial hardship.

Original amount 13,031,400 GBP, converted at the ECB reference rate of 26 Nov 2024.

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26 Nov 2024 András Sebők (ehem. Chief Supply Chain Officer der Wizz Air Holdings plc)Wizz Air: executive trades in closed periods and fails to notify own transactions United KingdomMarket abuse and insider dealing €147,940

In 2019–2020, the former Chief Supply Chain Officer András Sebők carried out 115 transactions in Wizz Air shares worth more than 4 million GBP, some of them in the 30-day closed periods before the publication of results, and did not notify them within three business days. First FCA penalty against a person discharging managerial responsibilities (PDMR) for dealing in a closed period: 123,500 GBP.

What organisations can take from it

Executives need annual instruction and a pre-clearance procedure for their own share dealings, including closed periods.

Relevance to training and awareness

Directors' dealings: closed periods and notification obligations of executives

Authority / court
Financial Conduct Authority (FCA)
Area of law
Capital markets and financial supervision · Market abuse and insider dealing
Legal basis
Art. 19 MAR
Action
Fine
Status of proceedings
final
Sector
Transport, logistics and shipping
Mitigating circumstances
30 % discount for settlement
Liability of senior managers
András Sebők (former Chief Supply Chain Officer): 123,500 GBP
Published
27 Nov 2024

Original amount 123,500 GBP, converted at the ECB reference rate of 26 Nov 2024.

Sources

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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 Nov 2024 Banus Port Vagyonkezelő Zrt.Banus Port: 250 million HUF for fictitious trading in 4iG shares HungaryMarket abuse and insider dealing €608,080

From September 2023 to May 2024, the asset management company used transactions worth several billion forints to create false signals about the trading volume of 4iG shares (‘painting the tape’). The Magyar Nemzeti Bank (Central Bank of Hungary, MNB) prohibited any repetition, imposed 250 million HUF and filed a criminal complaint.

What organisations can take from it

Transactions that mainly simulate turnover are market manipulation – even without a price target.

Authority / court
Magyar Nemzeti Bank (MNB)
Area of law
Capital markets and financial supervision · Market abuse and insider dealing
Legal basis
Art. 12, 15 MAR (Marktmanipulation), Beschluss H-PJ-III-B-26/2024
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Culpability
intentional
Published
22 Nov 2024

Original amount 250,000,000 HUF, 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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6 Nov 2024 Deželna banka Slovenije d. d.Deželna banka Slovenije: 90,000 EUR for deficient credit risk provisioning SloveniaOrganisational requirements €90,000

From 2018 to mid-2023, the bank had no adequate policies for impairments and provisions under IFRS 9 and the EBA guidelines on credit risk. Banka Slovenije (Bank of Slovenia) imposed 90,000 EUR on the bank and 2,500 EUR each on the chair of the management board and a board member.

What organisations can take from it

In Slovenia, governance deficiencies in risk management are also sanctioned personally against board members.

Authority / court
Banka Slovenije
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Art. 171, Art. 396 Abs. 1 Nr. 19 ZBan-3
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Liability of senior managers
Fines of 2,500 EUR each on the chair of the management board, Marko Rozman, and the board member Barbara Cerovšek Zupančič.

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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19 Jul 2024 Parrot SAParrot: misleading half-yearly report and insider dealing ahead of a takeover bid FranceMarket abuse and insider dealing €420,000

In its 2018 half-yearly report, the drone manufacturer disseminated misleading information on the absence of impairment indicators for the drone division, on goodwill and on earnings; in addition, the deputy managing director used inside information about a planned takeover bid. Sanctions: Parrot 150,000 EUR, CEO Henri Seydoux 60,000 EUR, Gilles Labossière 210,000 EUR.

What organisations can take from it

Impairment tests for loss-making divisions and trading bans for management are particularly sensitive in a takeover context.

Relevance to training and awareness

Insider dealing ban for executives in connection with takeover plans

Authority / court
Autorité des marchés financiers (AMF), Commission des sanctions
Area of law
Capital markets and financial supervision · Market abuse and insider dealing
Legal basis
Art. 12 Abs. 1 lit. c, Art. 15 MAR; Art. 8 und 14 MAR
Action
Fine
Status of proceedings
unknown
Sector
Telecoms, IT and software
Liability of senior managers
Henri Seydoux (Président-directeur général): 60,000 EUR; Gilles Labossière (directeur général délégué): 210,000 EUR, including for insider dealing
Sources

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

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20 Mar 2024 Scope Ratings GmbHScope Ratings: conflicts of interest not identified and disclosed – 2.2 million EUR EU levelOrganisational requirements €2.2m

The Berlin-based credit rating agency lacked adequate procedures, internal controls and organisational arrangements to deal with conflicts of interest, did not disclose a potential conflict and concealed ancillary services it had provided to a rated entity. ESMA found negligent infringements and imposed fines of 2,197,500 EUR.

What organisations can take from it

Systematically record and disclose ancillary services for customers whom you are at the same time rating or auditing.

Relevance to training and awareness

Identifying and disclosing conflicts of interest

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), Anhang III
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Culpability
negligent
Repeat case
yes
Published
22 Mar 2024

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

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1 Mar 2024 MTU Aero Engines AGMTU Aero Engines: inside information not disclosed without delay GermanyDisclosure and reporting obligations overturned

BaFin imposed a fine of 510,000 EUR on the engine manufacturer because it allegedly had not disclosed inside information without delay. Following an objection by the company, the Local Court of Frankfurt am Main (Amtsgericht) discontinued the proceedings on 21 January 2025 pursuant to Section 47 (2) OWiG (German Administrative Offences Act).

What organisations can take from it

Document the ad hoc assessment in such a way that the company can later substantiate its decision on the timing and content of a disclosure.

Relevance to training and awareness

Ad hoc disclosure: recognising inside information and disclosing it without delay

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
Action
Fine
Status of proceedings
overturned
Sector
Manufacturing and mechanical engineering
Published
20 Mar 2024

Amount in EUR; no ECB reference rate is available for this currency.

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

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22 Jan 2024 Hamburger Hafen und Logistik AGHHLA: failure to publish notices on financial reports GermanyDisclosure and reporting obligations €200,000

HHLA had not announced from when and at which internet address the 2021 annual financial report and the 2022 half-yearly financial report were publicly available. The fine has been final since 14 February 2024.

What organisations can take from it

Safeguard recurring mandatory publications by means of a checklist with named responsible persons and deadlines.

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
§ 114 Abs. 1 Satz 2 i. V. m. § 117 Nr. 1 und § 115 Abs. 1 Satz 2 i. V. m. § 117 Nr. 2 WpHG
Action
Fine
Status of proceedings
final
Sector
Transport, logistics and shipping
Published
2 Feb 2024

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

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7 Dec 2023 KION Group AGKION Group: ad hoc disclosure obligation breached, fine final GermanyDisclosure and reporting obligations €280,000

The intralogistics and forklift truck group had not disclosed inside information. BaFin imposed a fine of 280,000 EUR, which has been final since January 2024.

What organisations can take from it

Escalate potential inside information to the ad hoc disclosure committee immediately, not at the next reporting date.

Relevance to training and awareness

Ad hoc disclosure: recognising inside information and disclosing it without delay

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
Action
Fine
Status of proceedings
final
Sector
Manufacturing and mechanical engineering
Published
21 Dec 2023

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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