Compliance Radar

Who was sanctioned, and for what?

Fines, court rulings and incidents from Europe, North America, Latin America, Asia-Pacific, Middle East and Africa: 2,207 cases from 44 jurisdictions, each with an official source and checked against that source before publication. Filter by country, area of law and sector. Click a chart to drill down one level.

6cases from 3 jurisdictions
€69.5mTotal of monetary amounts
€29.7mLargest single case: Colas Rail Asia Sdn Bhd (Colas-Gruppe)
€8.98mMedian per case with an amount

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When?

per year, by date of decision
Trend
PeriodCasesTotal
20221€7.21m
20232€22.6m
20241€30,000
20250–
20262€39.7m

6 cases

19 Mar 2026 Colas Rail Asia Sdn Bhd (Colas-Gruppe)Colas Rail Asia: CJIP of 29.7 million EUR over bribery in metro contracts in Malaysia FranceBribery of public officials €29.7m

The Malaysian subsidiary of Colas Rail paid large, undocumented sums via intermediaries in connection with public contracts for urban rail lines in Kuala Lumpur (Kelana Jaya extension, MRT2). Following an internal investigation, Colas Rail self-reported the matter in 2017; the CJIP (Convention judiciaire d'intérêt public, a French deferred prosecution agreement) provides for a public interest fine of 29,745,974 EUR and a three-year compliance programme monitored by the French Anti-Corruption Agency (AFA) (costs of up to 1.9 million EUR).

What organisations can take from it

Undocumented payments to intermediaries on foreign projects must be stopped early by the finance and compliance functions – self-reporting after an internal investigation is rewarded.

Relevance to training and awareness

Intermediaries and consultants in public tenders

Authority / court
Parquet national financier (PNF); Validierung durch den Präsidenten des Tribunal judiciaire de Paris
Area of law
Bribery and corruption · Bribery of public officials
Legal basis
Art. 41-1-2 Code de procédure pénale (CJIP); Bestechung ausländischer Amtsträger
Action
Fine
Status of proceedings
final
Sector
Construction and real estate
Employees
10,000 or more
Culpability
intentional
Mitigating circumstances
Self-report (criminal complaint filed by Colas Rail on 31 May 2017) following an internal forensic investigation.
Liability of senior managers
The CJIP does not address the criminal liability of natural persons.
Published
19 Mar 2026

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

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10 Feb 2026 Strukton Civiel Projecten B.V. und Strukton International B.V. (Strukton-Gruppe)Construction group Strukton pays 10 million EUR out-of-court settlement over bribery on the Riyadh Metro NetherlandsBribery of public officials €10m

To secure a share in the Riyadh Metro project, around 31 million USD was paid between 2013 and 2021 to an agent representing a high-ranking member of the Saudi royal family; the agent payments were understated to the export credit insurer Atradius. Strukton accepted a transaction (out-of-court settlement) of 10 million EUR.

What organisations can take from it

Commissions to agents with ties to ruling families carry the highest risk – and false statements to export credit insurers constitute a second offence.

Relevance to training and awareness

Agent commissions and false statements to export credit insurers

Authority / court
Openbaar Ministerie (OM)
Area of law
Bribery and corruption · Bribery of public officials
Legal basis
Buitenlandse ambtelijke omkoping und valsheid in geschrift (Wetboek van Strafrecht); Transactie nach Art. 74 Sr
Action
Fine
Status of proceedings
final
Sector
Construction and real estate
Culpability
intentional
Mitigating circumstances
Cooperation from mid-2023; compliance programme in place since 2017; the employees involved are no longer with the company.
Published
30 Mar 2026

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

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17 Dec 2024 BAM International B.V.OM: penalty order for BAM International over misrecorded facilitation payments NetherlandsBribery of public officials €30,000

The Openbaar Ministerie (OM, Dutch Public Prosecution Service) imposed a penalty order of 30,000 EUR on BAM International B.V. for forgery (valsheid in geschrift): on a completed project in Africa, so-called facilitation payments had been made to officials in connection with a tax dispute, and not all of them were recorded transparently in the accounts. The company had discovered the payments in its own investigation and reported them itself; the amount reflects the OM guideline on self-reporting, cooperation and internal investigation. The OM dropped separate proceedings for bribery of public officials on other projects for lack of evidence.

What organisations can take from it

Even tolerated small payments to officials must be recorded completely and transparently; self-reporting and own investigation reduce the penalty.

Relevance to training and awareness

Facilitation payments and transparent bookkeeping

Authority / court
Openbaar Ministerie (OM), Functioneel Parket
Area of law
Bribery and corruption · Bribery of public officials
Legal basis
Valsheid in geschrift (Urkundenfälschung nach niederländischem Strafrecht); Strafbefehl des OM
Action
Fine
Status of proceedings
unknown
Sector
Construction and real estate
Mitigating circumstances
Self-reporting, own investigation and cooperation with the investigation.
Published
17 Dec 2024

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

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4 Dec 2023 a French engineering and design firmPNF: CJIP with an engineering firm for €14.6m over suspected foreign bribery FranceBribery of public officialsanonymised €14.6m

The engineering firm undertook to pay a public interest fine of 14,600,000 EUR under a CJIP (convention judiciaire d'intérêt public, French deferred prosecution agreement) concluded on 29 November 2023 and validated on 4 December 2023. The investigation, including for bribery of foreign public officials, stemmed from a criminal complaint through which the company itself had passed audit reports and an anonymous letter to the judicial authorities in 2013.

What organisations can take from it

Internal audit findings and anonymous tip-offs about bribery should be investigated immediately; self-reporting does not, however, rule out a later sanction.

Relevance to training and awareness

Handling internal indications of bribery, and self-reporting

Authority / court
Parquet national financier (PNF); Validierung durch den Präsidenten des Tribunal judiciaire de Paris
Area of law
Bribery and corruption · Bribery of public officials
Legal basis
Art. 41-1-2 Code de procédure pénale (corruption d'agent public étranger)
Action
Fine
Status of proceedings
final
Sector
Construction and real estate
Published
4 Dec 2023

Checked against the official source on 2 Oct 2026 · Company name anonymised since 4 Dec 2025 · Direct link

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17 May 2023 a French construction company and a property developer of the same construction groupPNF: CJIP with a construction company and a property developer for €7.96m FranceBribery of public officialsanonymised €7.96m

The two companies of a French construction group undertook, in a CJIP (convention judiciaire d'intérêt public, French deferred prosecution agreement), to pay a public interest fine totalling 7,964,000 EUR and to implement a three-year compliance programme under the supervision of the Agence française anticorruption (French anti-corruption agency), the costs of which the construction company bears up to 1,337,000 EUR. The investigation opened in 2021 concerned, among other things, favouritism in public procurement (favoritisme) and active and passive bribery of public officials; validated on 17 May 2023.

What organisations can take from it

Contacts with public contracting authorities during tender procedures must be clearly regulated and documented to avoid allegations of favouritism.

Relevance to training and awareness

Bribery and favouritism in public construction contracts

Authority / court
Parquet national financier (PNF); Validierung durch den Präsidenten des Tribunal judiciaire de Paris
Area of law
Bribery and corruption · Bribery of public officials
Legal basis
Art. 41-1-2 Code de procédure pénale (favoritisme, corruption d'agent public)
Action
Fine
Status of proceedings
final
Sector
Construction and real estate
Published
17 May 2023

Checked against the official source on 2 Oct 2026 · Company name anonymised since 17 May 2025 · Direct link

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11 Oct 2022 a Brazilian engineering and construction companyEngineering company: BRL 36.4m and debarment over collusion on a nuclear plant project BrazilBribery and corruptionanonymised €7.21m

The CGU imposed on a Brazilian engineering and construction company a fine of BRL 36,363,406.20, extraordinary publication of the decision and a declaration of unfitness for public contracts until rehabilitation. The basis was the frustration of competition in a state-owned nuclear power operator's tenders for the electromechanical assembly of a nuclear power plant through agreements with competitors (Art. 5 IV Lei 12.846/2013); the Minister considered the bribery allegation (Art. 5 I) insufficiently proven. The CGU rejected the request for reconsideration on 8 April 2024.

What organisations can take from it

In Brazil, price and lot-sharing agreements in public tenders are also punished under the Anti-Corruption Act – with a fine and exclusion from contracts.

Relevance to training and awareness

Price and lot-sharing agreements in public tenders

Authority / court
Controladoria-Geral da União (CGU)
Area of law
Bribery and corruption
Legal basis
Lei 12.846/2013, Art. 5 IV, Art. 6 I und II; Lei 8.666/1993, Art. 87 IV i. V. m. Art. 88 III; Decreto 8.420/2015
Action
Fine
Status of proceedings
final
Sector
Construction and real estate
Published
14 Oct 2022

Original amount 36,363,406.2 BRL, converted at the ECB reference rate of 11 Oct 2022.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 11 Oct 2024 · Direct link

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