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.

7cases from 4 jurisdictions
€864.9mTotal of monetary amounts
€316.9mLargest single case: a UK commodities trader
€90.5mMedian per case with an amount

Click a bar to drill down one level.

When?

per year, by date of decision
Trend
PeriodCasesTotal
20221€316.9m
20231€208.9m
20242€108.3m
20253€230.8m
20260–

7 cases

28 Mar 2025 Trafigura Beheer B.V.Trafigura Beheer: leniency agreement with CGU and AGU for BRL 435.4m BrazilBribery of public officials €69.9m

Trafigura Beheer B.V. entered into a leniency agreement with the Controladoria-Geral da União (CGU, Office of the Comptroller General) and the Advocacia-Geral da União (AGU, Office of the Attorney General) in which it admitted paying undue advantages to public officials and using front persons to conceal its interests. It allegedly pays BRL 435,410,672.26: BRL 153,710,689.11 within ten days (the conversion of USD 26,829,346; under its agreement with the US Department of Justice on a fine of USD 80,488,040, this part of the US fine may be offset by the payment to the Brazilian authorities) and BRL 281,699,983.15 (the conversion of USD 49,169,165.53) as the remaining balance. The amount and the facts have not been confirmed against the primary source.

What organisations can take from it

In corruption cases involving several countries, double payments can be avoided through coordinated agreements with all the authorities involved.

Relevance to training and awareness

Payments to public officials and use of intermediaries

Authority / court
Controladoria-Geral da União (CGU) und Advocacia-Geral da União (AGU)
Area of law
Bribery and corruption · Bribery of public officials
Legal basis
Lei nº 12.846/2013, Art. 5 I und III, Art. 16; Lei nº 8.429/1992; Decreto nº 11.129/2022
Action
Fine
Status of proceedings
final
Sector
Energy and utilities
Mitigating circumstances
Coordination with the US proceedings so that part of the Brazilian payment can be credited against the US fine; obligation to improve the integrity programme under CGU monitoring for 36 months.

Original amount 435,410,672.26 BRL, converted at the ECB reference rate of 28 Mar 2025.

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

Report an error

Anonymous: we store only your text, no contact details and no IP address.

11 Feb 2025 Paprec GroupPNF: CJIP with Paprec Group for €17.54m after investigation into waste contracts FranceBribery of public officials €17.5m

Paprec Group undertook, in a CJIP (convention judiciaire d'intérêt public, French deferred prosecution agreement), to pay a public interest fine of 17,538,990 EUR, including 4,828,000 EUR already seized, and to implement a three-year compliance programme under the supervision of the Agence française anticorruption (French anti-corruption agency) (costs up to 1,000,000 EUR). The background is a judicial investigation including for bribery, favouritism in procurement, money laundering and unlawful agreements concerning contracts and concessions of French local authorities for waste treatment; validated on 11 February 2025.

What organisations can take from it

Companies that depend on municipal contracts must systematically review contacts with decision-makers and tender processes for bribery and favouritism risks.

Relevance to training and awareness

Integrity in municipal contracts and concessions

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
Action
Fine
Status of proceedings
final
Sector
Energy and utilities
Published
11 Feb 2025

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

Report an error

Anonymous: we store only your text, no contact details and no IP address.

31 Jan 2025 Trafigura Beheer B.V.Swiss Federal Criminal Court (Bundesstrafgericht) convicts Trafigura of bribery in Angola SwitzerlandBribery of public officials €143.3m

Between 2009 and 2011, more than 4 million EUR and more than 600,000 USD were paid to an official in Angola in order to promote ship chartering and bunkering business of the Trafigura group. The court convicted the then parent company for lacking rules on the supervision of intermediaries, imposing a fine of 3 million CHF and a compensatory claim (Ersatzforderung) of 145,634,268 USD (amount converted at the ECB rate of 31 January 2025: 148,933,982 USD in total). It was the first judgment of the Federal Criminal Court on corporate criminal liability for foreign bribery; it is not final.

What organisations can take from it

In Switzerland, companies are liable if their organisation fails to prevent bribery – and the compensatory claim can exceed the fine many times over.

Relevance to training and awareness

Payments via intermediaries to employees of state-owned oil companies

Authority / court
Bundesstrafgericht (Strafkammer); Anklage durch die Bundesanwaltschaft
Area of law
Bribery and corruption · Bribery of public officials
Legal basis
Art. 102 StGB i. V. m. Art. 322septies StGB (Bestechung fremder Amtsträger); SK.2023.49
Action
Fine
Status of proceedings
unknown
Sector
Energy and utilities
Employees
10,000 or more
Culpability
intentional
Published
31 Jan 2025

Original amount 148,933,982 USD, converted at the ECB reference rate of 31 Jan 2025.

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

Report an error

Anonymous: we store only your text, no contact details and no IP address.

14 Nov 2024 Freepoint Commodities LLCFreepoint Commodities: leniency agreement worth BRL 131.25m over bribery BrazilBribery of public officials €17.8m

The US company Freepoint Commodities LLC admitted, in a leniency agreement with the CGU and the AGU, to having paid undue advantages to public officials through intermediaries (Art. 5 I and III Lei 12.846/2013) and allegedly pays BRL 108,710,739.68 as a fine plus disgorgement. According to Annex III, BRL 60,919,037.14 is the fine payable to the Union (after a 67% reduction) and BRL 47,791,702.54 is disgorgement. Damages to Petrobras of BRL 22,542,907.62 are set out only in the text. The agreement also stated a total of BRL 131,253,647.32 (USD 22,744,839.85); the two centavos by which that total exceeds the fine, the disgorgement and the damages are not smoothed. If the company resumes business in Brazil within five years, it must adapt its compliance programme to Brazilian law and report to the CGU. The amount and the facts have not been confirmed against the primary source.

What organisations can take from it

Companies that win business through intermediaries must control their payments to officials – otherwise the company itself is liable.

Relevance to training and awareness

Bribery of public officials through intermediaries

Authority / court
Controladoria-Geral da União (CGU) und Advocacia-Geral da União (AGU)
Area of law
Bribery and corruption · Bribery of public officials
Legal basis
Lei 12.846/2013, Art. 5 I und III, Art. 6 I, Arts. 16, 17 und 19 I; Lei 8.429/1992; Decreto 11.129/2022
Action
Fine
Status of proceedings
final
Sector
Energy and utilities
Mitigating circumstances
Credit was given for remediation of damage (1%), cooperation (1.5%) and voluntary admission (2%); no reduction was granted for a compliance programme.
Liability of senior managers
Tolerance or knowledge by management was applied as an aggravating factor at 2.5%.

Original amount 108,710,739.68 BRL, converted at the ECB reference rate of 14 Nov 2024.

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

Report an error

Anonymous: we store only your text, no contact details and no IP address.

1 Mar 2024 a Swiss commodities trading houseTrading house convicted: around 86.7 million CHF over corruption in Ecuador's oil business SwitzerlandBribery of public officialsanonymised €90.5m

The Geneva-based commodities trading house failed to take all reasonable organisational precautions to prevent foreign public officials from being bribed on its behalf in connection with the Ecuadorian oil industry from 2013 to 2017. The Office of the Attorney General of Switzerland (BA) – in coordination with US authorities – ordered the trading house to pay around 86.7 million CHF, of which 4.3 million CHF is a fine.

What organisations can take from it

Commodities traders must scrutinise payments to intermediaries in government business without gaps – the confiscation of profits far exceeds the fine.

Relevance to training and awareness

Payments via intermediaries to state-owned oil companies

Authority / court
Bundesanwaltschaft (BA)
Area of law
Bribery and corruption · Bribery of public officials
Legal basis
Art. 102 StGB (Unternehmensverantwortlichkeit) i. V. m. Bestechung fremder Amtsträger
Action
Fine
Status of proceedings
unknown
Sector
Energy and utilities
Culpability
intentional
Published
1 Mar 2024

Original amount 86,700,000 CHF, converted at the ECB reference rate of 1 Mar 2024.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 1 Mar 2026 · Direct link

Report an error

Anonymous: we store only your text, no contact details and no IP address.

28 Jun 2023 a French and a British energy engineering company of the same groupPNF: CJIP with two energy engineering companies for €208.94m FranceBribery of public officialsanonymised €208.9m

Two companies of a former energy engineering group concluded a CJIP (convention judiciaire d'intérêt public, French deferred prosecution agreement) with the Parquet national financier (PNF, French national financial prosecutor) over possible bribery of foreign public officials in connection with contracts concluded in 2008 and 2009 in Ghana and Equatorial Guinea. The French company pays a public interest fine of 54,146,000 EUR and the British company 154,792,000 EUR, 208,938,000 EUR in total; the agreement was validated on 28 June 2023.

What organisations can take from it

In large contracts with state energy companies, intermediaries' contacts with public officials and their relatives must be scrutinised with particular care.

Relevance to training and awareness

Bribery of foreign public officials in major energy projects

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
Energy and utilities
Published
28 Jun 2023

Checked against the official source on 2 Oct 2026 · Company name anonymised since 28 Jun 2025 · Direct link

Report an error

Anonymous: we store only your text, no contact details and no IP address.

3 Nov 2022 a UK commodities traderUK commodities trader: around 276 million GBP in fines and confiscation for bribery to gain access to oil United KingdomBribery of public officialsanonymised €316.9m

With the company's approval, agents and employees of the London oil trading division paid more than 25 million USD in bribes for preferential access to oil in Nigeria, Cameroon, Côte d'Ivoire, Equatorial Guinea, Ghana, South Sudan and Malawi. Following guilty pleas to seven counts, the court imposed fines of 182,935,392 GBP and a confiscation order of 93,479,338.95 GBP (276,414,730.95 GBP in total), plus 4,550,362 GBP in costs.

What organisations can take from it

In commodities trading, access to cargoes determines profits – that is exactly where strict controls over agents and cash are needed.

Relevance to training and awareness

Cash and agents in commodities trading

Authority / court
Serious Fraud Office (SFO); Southwark Crown Court
Area of law
Bribery and corruption · Bribery of public officials
Legal basis
Bribery Act 2010, s. 1 (fünf Fälle) und s. 7 (zwei Fälle); Proceeds of Crime Act 2002 (Confiscation)
Action
Fine
Status of proceedings
final
Sector
Energy and utilities
Employees
10,000 or more
Culpability
intentional
Published
3 Nov 2022

Original amount 276,414,730.95 GBP, converted at the ECB reference rate of 3 Nov 2022.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 3 Nov 2024 · Direct link

Report an error

Anonymous: we store only your text, no contact details and no IP address.

Ready for training that actually lands?

Try the combination for free: automated administration for you, learning formats that fit your team, with no minimum or credit card.

Start 14-day free trial