Compliance Radar

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Fines, court rulings and incidents from Europe, North America, Latin America, Asia-Pacific and Middle East: 1,929 cases from 40 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.

Bribery and corruption Financial services and insurance MMM Holdings, LLC Clear all filters

1case from 1 jurisdiction

€14.7mTotal of monetary amounts

€14.7mLargest single case: MMM Holdings, LLC

€14.7mMedian per case with an amount

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USA €14.7m 100 % · 1 case

What for?

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Gifts, hospitality and benefits €14.7m 100 % · 1 case

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When?

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Trend
Period	Cases	Total
Q4 2023	0	–
Q1 2024	0	–
Q2 2024	0	–
Q3 2024	0	–
Q4 2024	1	€14.7m
Q1 2025	0	–
Q2 2025	0	–
Q3 2025	0	–
Q4 2025	0	–
Q1 2026	0	–
Q2 2026	0	–
Q3 2026	0	–
Q4 2026	0	–

1 case

Newest first Highest amounts

23 Dec 2024 MMM Holdings, LLCMMM Holdings: USD 15.2m over gift cards for Medicare plan enrolments USAGifts, hospitality and benefits €14.7m

The Puerto Rico Medicare Advantage provider pays USD 15,228,340 to resolve False Claims Act and Anti-Kickback Statute allegations and entered into a five-year Corporate Integrity Agreement with HHS-OIG. From January 2018 to December 2022 MMM allegedly gave gift cards to administrative assistants of medical practices so that they would get thousands of Medicare beneficiaries to enrol in an MMM plan; the resulting premium payments amounted to USD 6,091,336.

What organisations can take from it

Gifts to practice staff who advise insured patients are as sensitive as benefits to doctors.

Relevance to training and awareness

Gifts to practice staff who advise or refer patients

Authority / court: U.S. Attorney's Office, District of Puerto Rico; HHS Office of Inspector General (HHS-OIG)
Area of law: Bribery and corruption · Gifts, hospitality and benefits
Legal basis: False Claims Act; Anti-Kickback Statute
Action: Other
Status of proceedings: final
Sector: Financial services and insurance
Mitigating circumstances: The company's cooperation and its implementation of internal controls were taken into account.
Published: 23 Dec 2024

Original amount 15,228,340 USD, converted at the ECB reference rate of 23 Dec 2024.

Sources

MMM Holdings, LLC Agrees to Pay 15.2 Million Dollars to Resolve Allegations that it Violated the False Claims Act and Anti-Kickback Statute (USAO D.P.R., 23.12.2024) Press release of an authority

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

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Official sources only

Every case is based on a decision, press release or database of an authority or a court. Press and law-firm reports count at most as additional references.

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Whoever enters a case may not approve it. A second, independent check compares company, date, amount and area of law with the source. Only then is the case published.

Comparable amounts

Amounts are converted at the ECB reference rate on the day of the decision. Each case also shows the original amount.

Corrections on record

A correction is a new version that is checked again. Every change is logged. You can report errors directly on each case.

Case texts are translated from the German original. Where a translation is not yet available, the German text is shown and marked “(German original)”. Names of authorities, laws and companies are given as in the source (company names until they are anonymised).

Company names are anonymised two years after the decision in a case, in line with the practice of many supervisory authorities. The official sources remain linked.

The radar reports on published decisions and is not legal advice. Decisions that are not yet final are marked as such where the status is known.

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