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.

Bribery and corruptionHealthcare Clear all filters
18cases from 3 jurisdictions
€246.2mTotal of monetary amounts
€56.9mLargest single case: a Dutch medical technology group
€8.12mMedian per case with an amount

Click a bar to drill down one level.

by amountby number of cases

Where?

by region

All jurisdictions

  1. USA €232.7m 95 % · 15 cases
  2. Brazil €11.7m 5 % · 2 cases
  3. EU €1.77m 1 % · 1 case

What for?

by topic
  1. Commercial bribery €136.5m 55 % · 10 cases
  2. Bribery of public officials €59.7m 24 % · 3 cases
  3. Gifts, hospitality and benefits €38.2m 16 % · 3 cases
  4. no topic €11.7m 5 % · 2 cases

Who?

by company
  1. Anonymised companies €113.8m 46 % · 6 cases
  2. Access DX Laboratory, LLC €31.7m 13 % · 1 case
  3. Advanced Pathology Solutions PLLC und APS MSO LLC €25.9m 11 % · 1 case
  4. C.R. Bard, Inc.; Liberator Medical Supply, Inc.; Liberator Holdings; Rochester Medical Corporation €16.3m 7 % · 1 case
  5. NUWAY Alliance, Inc. €15.8m 6 % · 1 case
  6. Oroville Hospital €9.77m 4 % · 1 case
  7. NeoGenomics Laboratories Inc. €8.59m 3 % · 1 case
  8. Associação da Irmandade da Santa Casa de Misericórdia de Pacaembu €7.65m 3 % · 1 case
  9. Modern Nuclear Inc. €7.12m 3 % · 1 case
  10. New York-Presbyterian Hudson Valley Hospital €5.79m 2 % · 1 case
  11. 3 more€3.66m

When?

per year, by date of decision
Trend
PeriodCasesTotal
20232€63m
20245€60.6m
20254€45.6m
20267€77m

18 cases

Newest firstHighest amounts
30 Jul 2026 Access DX Laboratory, LLCAccess DX Laboratory: 36.4 million USD – kickbacks for unnecessary genetic tests USACommercial bribery €31.7m

The Houston laboratory allegedly paid kickbacks and billed Medicare and Medicaid for medically unnecessary genetic tests. The settlements with the laboratory and other parties add up to 36.4 million USD (combined total); the laboratory is subject to a Corporate Integrity Agreement.

What organisations can take from it

Commission models for intermediaries who bring in orders or patients are a classic gateway for bribery.

Relevance to training and awareness

Remuneration of intermediaries and referrers

Authority / court
U.S. Department of Justice
Area of law
Bribery and corruption · Commercial bribery
Legal basis
Anti-Kickback Statute (42 U.S.C. § 1320a-7b(b)); False Claims Act (31 U.S.C. §§ 3729 ff.)
Action
Other
Status of proceedings
final
Sector
Healthcare
Liability of senior managers
Measures against individuals are not reported here.

Original amount 36,400,000 USD, converted at the ECB reference rate of 30 Jul 2026.

Sources

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

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20 Jul 2026 NeoGenomics Laboratories Inc.NeoGenomics: 9.8 million USD after self-disclosure – discounted consulting for referring physicians USACommercial bribery €8.59m

The Florida laboratory provided referring physicians with consulting services below market value and paid independent consultants referral-based remuneration for recruiting physicians. Following a self-disclosure, NeoGenomics paid 9,813,260 USD.

What organisations can take from it

Free or discounted services are also benefits – like cash payments, they belong in the anti-corruption review.

Relevance to training and awareness

Services with monetary value provided to customers below market value

Authority / court
U.S. Department of Justice
Area of law
Bribery and corruption · Commercial bribery
Legal basis
Anti-Kickback Statute (42 U.S.C. § 1320a-7b(b)); False Claims Act (31 U.S.C. §§ 3729 ff.)
Action
Other
Status of proceedings
final
Sector
Healthcare
Mitigating circumstances
Self-disclosure of the remuneration arrangements.

Original amount 9,813,260 USD, converted at the ECB reference rate of 20 Jul 2026.

Sources

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

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17 Jun 2026 Advanced Pathology Solutions PLLC und APS MSO LLCAdvanced Pathology Solutions: 30 million USD for kickbacks and unnecessary laboratory tests USACommercial bribery €25.9m

The Arkansas pathology laboratory and its management company allegedly granted unlawful kickbacks and ordered medically unnecessary tests. The settlement of 30 million USD is a joint payment by all settling parties; the laboratory entered into a Corporate Integrity Agreement.

What organisations can take from it

Where services are sold through referrals, all benefits to referrers belong in a central approval and review procedure.

Relevance to training and awareness

Benefits to clients in healthcare

Authority / court
U.S. Department of Justice
Area of law
Bribery and corruption · Commercial bribery
Legal basis
Anti-Kickback Statute (42 U.S.C. § 1320a-7b(b)); False Claims Act (31 U.S.C. §§ 3729 ff.)
Action
Other
Status of proceedings
final
Sector
Healthcare
Liability of senior managers
Measures against individuals are not reported here.

Original amount 30,000,000 USD, converted at the ECB reference rate of 17 Jun 2026.

Sources

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

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1 May 2026 Modern Nuclear Inc.Modern Nuclear: 8.33 million USD – excessive supervision fees paid to referring cardiologists USACommercial bribery €7.12m

The Californian provider of mobile PET scans allegedly paid referring cardiologists excessive fees for supervising the examinations in order to secure referrals. The settlement of 8,334,350.71 USD plus revenue-based payments is based on ability to pay; in addition, there is a Corporate Integrity Agreement.

What organisations can take from it

Remuneration of business partners who refer work must correspond to the market value of the service – any overpayment acts as a bribe.

Relevance to training and awareness

Checking fee agreements with referrers for market conformity

Authority / court
U.S. Department of Justice / U.S. Attorney's Office, Central District of California
Area of law
Bribery and corruption · Commercial bribery
Legal basis
Anti-Kickback Statute (42 U.S.C. § 1320a-7b(b)); False Claims Act (31 U.S.C. §§ 3729 ff.)
Action
Other
Status of proceedings
final
Sector
Healthcare

Original amount 8,334,350.71 USD, converted at the ECB reference rate of 30 Apr 2026.

Sources

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

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19 Mar 2026 Balt USA LLC (Balt-Gruppe)Balt USA: CJIP in France over payments to a hospital physician FranceBribery of public officials €1.77m

In parallel with the US declination, the PNF concluded a CJIP with the US subsidiary of the French medical technology manufacturer for 1,765,493 EUR (after crediting the US disgorgement) and a three-year AFA compliance programme. The case arose from Balt SAS's voluntary self-disclosure of 22 May 2023 concerning conduct at the acquired company Blockade Medical.

What organisations can take from it

Acquisitions require anti-corruption due diligence on the target company – otherwise legacy misconduct by its management becomes a group risk.

Relevance to training and awareness

Benefits to hospital physicians, integration of acquired companies

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); aktive und passive Bestechung von Amtsträgern
Action
Fine
Status of proceedings
final
Sector
Healthcare
Employees
250 to 999
Culpability
intentional
Mitigating circumstances
Voluntary self-disclosure to the PNF and the DOJ; coordinated resolution with crediting.
Liability of senior managers
The CJIP does not address the criminal liability of natural persons.
Published
19 Mar 2026
Sources

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

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17 Mar 2026 Balt SAS / Balt USA LLCMedical technology: DOJ declination for Balt SAS after bribery of a hospital physician USABribery of public officials €1.05m

Through sham consultancy agreements, fictitious invoices and purported bonus payments, around 602,000 USD in bribes flowed from 2017 to 2023 via a Belgian consultant to a physician in a senior position at a French public hospital, so that the hospital would purchase embolisation coils from Balt. The DOJ declined to prosecute on account of voluntary self-disclosure, cooperation and remediation (declination of 17 March 2026); Balt is disgorging 1,214,797 USD in profits.

What organisations can take from it

Physicians at public hospitals are public officials – consultancy agreements with them require documented services and approval by the compliance function.

Relevance to training and awareness

Benefits to physicians in the public healthcare sector, sham consultancy agreements

Authority / court
U.S. Department of Justice (Criminal Division, Fraud Section)
Area of law
Bribery and corruption · Bribery of public officials
Legal basis
FCPA; Corporate Enforcement and Voluntary Self-Disclosure Policy (Declination)
Action
Disgorgement of profits
Status of proceedings
final
Sector
Healthcare
Culpability
intentional
Mitigating circumstances
Voluntary self-disclosure (including to the French national financial prosecutor's office, PNF), full cooperation, timely remediation, disciplinary measures, parallel resolution in France.
Liability of senior managers
Measures against individuals are not reported here.
Published
19 Mar 2026

Original amount 1,214,797 USD, converted at the ECB reference rate of 17 Mar 2026.

Sources

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

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5 Mar 2026 Allin IP DX LLCAllin IP DX: 980,000 USD after self-disclosure over paid referral marketers USACommercial bribery €843,519

Between January and June 2023, the Sarasota laboratory paid independent marketers to steer laboratory samples from Medicare beneficiaries to it. It self-disclosed the conduct, cooperated extensively and paid 980,000 USD.

What organisations can take from it

Early self-disclosure limits the damage – but this requires the compliance function to actually get to see problematic sales contracts.

Relevance to training and awareness

Success-based remuneration of sales partners

Authority / court
U.S. Attorney's Office, Middle District of Florida
Area of law
Bribery and corruption · Commercial bribery
Legal basis
Anti-Kickback Statute (42 U.S.C. § 1320a-7b(b)); False Claims Act (31 U.S.C. §§ 3729 ff.)
Action
Other
Status of proceedings
final
Sector
Healthcare
Mitigating circumstances
Voluntary self-disclosure, detailed disclosure and cooperation.

Original amount 980,000 USD, converted at the ECB reference rate of 5 Mar 2026.

Sources

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22 Dec 2025 New York-Presbyterian Hudson Valley HospitalNYP Hudson Valley Hospital: 6.8 million USD for payments to referring practice USACommercial bribery €5.79m

The hospital (until 2015 Hudson Valley Hospital Center) allegedly paid an oncology practice in Westchester millions of dollars to induce it to refer patients to the hospital; the hospital billed the services to Medicare and Medicaid. The U.S. Attorney’s Office filed a complaint and at the same time concluded a settlement of 6.8 million USD.

What organisations can take from it

Cooperation agreements between hospitals and office-based practices must properly document services and remuneration – otherwise payments are treated as referral bonuses.

Relevance to training and awareness

Payments to referrers in hospitals

Authority / court
U.S. Attorney's Office, Southern District of New York
Area of law
Bribery and corruption · Commercial bribery
Legal basis
Anti-Kickback Statute (42 U.S.C. § 1320a-7b(b)); False Claims Act (31 U.S.C. §§ 3729 ff.)
Action
Other
Status of proceedings
final
Sector
Healthcare

Original amount 6,800,000 USD, converted at the ECB reference rate of 22 Dec 2025.

Sources

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26 Jun 2025 NUWAY Alliance, Inc.NUWAY Alliance: USD 18.5m over payments to Medicaid patients and double billing USAGifts, hospitality and benefits €15.8m

The Minnesota provider of outpatient addiction treatment pays USD 18,500,000 to resolve False Claims Act allegations and entered into a five-year Corporate Integrity Agreement with HHS-OIG. According to the US Attorney's Office, from January 2019 to February 2025 NUWAY compensated Medicaid patients for attending intensive outpatient treatment and also billed services in which the same period of time was counted twice. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

Cash or in-kind incentives to patients for using reimbursable services are prohibited kickbacks under US law.

Relevance to training and awareness

Incentives to patients for using reimbursable services

Authority / court
U.S. Attorney's Office, District of Minnesota (U.S. Department of Justice)
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
Healthcare
Published
26 Jun 2025

Original amount 18,500,000 USD, converted at the ECB reference rate of 26 Jun 2025.

Sources

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23 Jan 2025 C.R. Bard, Inc.; Liberator Medical Supply, Inc.; Liberator Holdings; Rochester Medical CorporationC.R. Bard: USD 17m over discounts and free samples for urology practices USAGifts, hospitality and benefits €16.3m

Bard and three affiliated companies pay USD 17 million to resolve allegations under the federal False Claims Act and several state statutes. Between 2016 and February 2020 they allegedly gave urology practices discounts, excessive free samples and savings on office supplies so that they would prescribe intermittent catheters by default using Bard's own “Link” prescription form; no liability was determined.

What organisations can take from it

Free samples and discounts must never be linked to prescribing routes that benefit one's own sales.

Relevance to training and awareness

Free samples and discounts in medical device sales

Authority / court
U.S. Attorney's Office, Northern District of Georgia (U.S. Department of Justice)
Area of law
Bribery and corruption · Gifts, hospitality and benefits
Legal basis
False Claims Act; Anti-Kickback Statute (42 U.S.C. § 1320a-7b); False-Claims-Gesetze mehrerer Bundesstaaten
Action
Other
Status of proceedings
final
Sector
Healthcare
Published
23 Jan 2025

Original amount 17,000,000 USD, converted at the ECB reference rate of 23 Jan 2025.

Sources

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23 Jan 2025 Associação da Irmandade da Santa Casa de Misericórdia de PacaembuSanta Casa de Pacaembu: BRL 47.4m for fraud in hospital management contracts BrazilBribery and corruption €7.65m

The Controladoria-Geral da União (CGU, Office of the Comptroller General) imposed on the Associação da Irmandade da Santa Casa de Misericórdia de Pacaembu, an association operating as a healthcare social organisation (Organização Social), a fine of BRL 47,391,386.87, extraordinary publication of the decision and a declaration of unsuitability for public contracts. According to the final report, the association rigged the selection procedure for managing the Hangar field hospital in Belém (Pará), committed fraud in performing the management contract for a regional hospital in Belém and used front persons and companies to conceal its real interests.

What organisations can take from it

Associations that run hospitals on behalf of the state are also liable under the Anti-Corruption Law, and their leaders can be held personally liable.

Relevance to training and awareness

Integrity in selection procedures and management contracts in healthcare

Authority / court
Controladoria-Geral da União (CGU)
Area of law
Bribery and corruption
Legal basis
Lei nº 12.846/2013, Art. 5 III und IV b und d, Art. 6, Art. 14; Lei nº 8.666/1993, Art. 87 IV und Art. 88 II und III
Action
Fine
Status of proceedings
final
Sector
Healthcare
Liability of senior managers
Measures against individuals are not set out here.
Published
28 Jan 2025

Original amount 47,391,386.87 BRL, converted at the ECB reference rate of 23 Jan 2025.

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12 Dec 2024 Oroville HospitalOroville Hospital: USD 10.25m over admission bonuses for doctors and false billing USACommercial bribery €9.77m

The Californian hospital pays USD 10,250,000 (USD 9,518,954 to the federal government, USD 731,046 to the State of California) and entered into a five-year Corporate Integrity Agreement with HHS-OIG. The allegations were that it paid doctors who decided on inpatient admissions bonuses based on the number of patients admitted, billed medically unnecessary inpatient admissions and used false diagnosis codes for SIRS. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

Bonus schemes for doctors must not be linked to the number of admissions or referrals.

Relevance to training and awareness

Bonus schemes for doctors and referral incentives in hospitals

Authority / court
U.S. Attorney's Office, Eastern District of California (U.S. Department of Justice)
Area of law
Bribery and corruption · Commercial bribery
Legal basis
False Claims Act; Anti-Kickback Statute
Action
Other
Status of proceedings
final
Sector
Healthcare
Published
12 Dec 2024

Original amount 10,250,000 USD, converted at the ECB reference rate of 12 Dec 2024.

Sources

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18 Jul 2024 a major US dialysis groupUS dialysis group: 34.5 million USD – kickbacks for referrals to dialysis centres and pharmacy USACommercial briberyanonymised €31.6m

The dialysis group allegedly paid kickbacks to promote referrals to its former pharmacy subsidiary and granted benefits to nephrologists and vascular surgeons to induce them to send patients to the group's dialysis centres. The group paid 34,487,390 USD.

What organisations can take from it

Intra-group routing of customers to subsidiaries must not be bought with benefits for third parties.

Relevance to training and awareness

Benefits for referrers

Authority / court
U.S. Department of Justice
Area of law
Bribery and corruption · Commercial bribery
Legal basis
Anti-Kickback Statute (42 U.S.C. § 1320a-7b(b)); False Claims Act (31 U.S.C. §§ 3729 ff.)
Action
Other
Status of proceedings
final
Sector
Healthcare
Employees
10,000 or more

Original amount 34,487,390 USD, converted at the ECB reference rate of 18 Jul 2024.

Sources

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1 Jul 2024 three US home health agencies and their parent companyUS home health group: 4.5 million USD – kickbacks to senior living facilities and physicians USACommercial briberyanonymised €4.18m

Three home health agencies in Texas, Ohio and Indiana and their parent company allegedly granted kickbacks to assisted living facilities and physicians for Medicare referrals. They paid 4,496,330 USD.

What organisations can take from it

Cooperation with facilities that refer customers requires written contracts with remuneration at market rates and regular review.

Relevance to training and awareness

Benefits for cooperation partners who refer customers

Authority / court
U.S. Department of Justice
Area of law
Bribery and corruption · Commercial bribery
Legal basis
Anti-Kickback Statute (42 U.S.C. § 1320a-7b(b)); False Claims Act (31 U.S.C. §§ 3729 ff.)
Action
Other
Status of proceedings
final
Sector
Healthcare

Original amount 4,496,330 USD, converted at the ECB reference rate of 1 Jul 2024.

Sources

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29 May 2024 a US manufacturer of spinal implantsUS implant manufacturer: 12 million USD – kickbacks to spine surgeons USACommercial briberyanonymised €11.1m

The Utah manufacturer of spinal implants allegedly paid surgeons kickbacks to induce them to use the manufacturer's products. The settlement of 12 million USD is a joint payment by the company and other settling parties; HHS-OIG placed the company under heightened scrutiny.

What organisations can take from it

Consultancy agreements, royalty payments or fees to users who decide on the use of products require proof of need and a fair market value review.

Relevance to training and awareness

Payments to users of medical devices

Authority / court
U.S. Department of Justice
Area of law
Bribery and corruption · Commercial bribery
Legal basis
Anti-Kickback Statute (42 U.S.C. § 1320a-7b(b)); False Claims Act (31 U.S.C. §§ 3729 ff.)
Action
Other
Status of proceedings
final
Sector
Healthcare
Liability of senior managers
Measures against individuals are not reported here.

Original amount 12,000,000 USD, converted at the ECB reference rate of 29 May 2024.

Sources

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9 Jan 2024 a Brazilian healthcare services companyHealthcare services company: BRL 21.7m and debarment over medicine contracts BrazilBribery and corruptionanonymised €4.06m

The Controladoria-Geral da União (CGU, Office of the Comptroller General) imposed on a healthcare services company a fine of BRL 21,697,740.49, extraordinary publication of the decision and a declaration of unsuitability for public contracts. According to the final report, in Ministry of Health tenders for medicines for rare diseases (Aldurazyme, Myozyme, Fabrazyme) the company had submitted bids without being authorised to market these products, failed to deliver the agreed quantities on time and appropriated advance payments to the detriment of the Treasury. The CGU rejected its request for reconsideration on 15 June 2025.

What organisations can take from it

In public tenders, companies may only offer what they are legally and practically able to deliver.

Relevance to training and awareness

Bidding and contract performance in public procurement

Authority / court
Controladoria-Geral da União (CGU)
Area of law
Bribery and corruption
Legal basis
Lei nº 12.846/2013, Art. 5 IV b und d, Art. 6; Lei nº 8.666/1993, Art. 87 IV und Art. 88 II und III
Action
Fine
Status of proceedings
final
Sector
Healthcare
Published
12 Jan 2024

Original amount 21,697,740.49 BRL, converted at the ECB reference rate of 9 Jan 2024.

Sources

Checked against the official source on 7 Oct 2026 · Company name anonymised since 9 Jan 2026 · Direct link

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25 Aug 2023 a US conglomerateUS conglomerate: foreign trips for Chinese hospital officials cost 6.6 million USD USAGifts, hospitality and benefitsanonymised €6.09m

From 2014 to 2018, employees of the group's Chinese subsidiary invited healthcare officials of state-owned customers abroad to purported conferences and training courses that in reality often consisted of sightseeing and entertainment; payment was made via a complicit travel agency. Payment of 3,538,897 USD in disgorgement, 1,042,721 USD in interest and a penalty of 2 million USD.

What organisations can take from it

Training trips for public-sector customers require a professional programme, prior approval and supporting documentation – tourism components are impermissible benefits.

Relevance to training and awareness

Invitations to events and trips for public officials

Authority / court
U.S. Securities and Exchange Commission (SEC)
Area of law
Bribery and corruption · Gifts, hospitality and benefits
Legal basis
FCPA Buchführungs- und interne Kontrollvorschriften
Action
Fine
Status of proceedings
final
Sector
Healthcare
Employees
10,000 or more
Culpability
intentional
Mitigating circumstances
Prompt self-report upon becoming aware, cooperation (including witnesses and documents) and extensive remedial measures.
Published
25 Aug 2023

Original amount 6,581,618 USD, converted at the ECB reference rate of 25 Aug 2023.

Sources

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11 May 2023 a Dutch medical technology groupMedical technology group pays 62 million USD to the SEC over bribery in Chinese hospital tenders USABribery of public officialsanonymised €56.9m

From 2014 to 2019, employees, distributors and sub-distributors of the group's Chinese subsidiary improperly influenced the technical specifications of public hospital tenders and organised sham bids with products from other manufacturers; special discounts to distributors also created the risk that inflated margins financed payments to employees of state-owned hospitals. Payment of 41,126,170 USD in disgorgement, 6,047,633 USD in interest and a penalty of 15 million USD; the group had already been sanctioned in 2013 for similar conduct in Poland.

What organisations can take from it

Monitor unusually high discounts or margins for distributors as a corruption risk – regulators come down harder on repeat offenders.

Relevance to training and awareness

Distributor margins as a slush fund, influence on tender specifications

Authority / court
U.S. Securities and Exchange Commission (SEC)
Area of law
Bribery and corruption · Bribery of public officials
Legal basis
FCPA Buchführungs- und interne Kontrollvorschriften
Action
Fine
Status of proceedings
final
Sector
Healthcare
Employees
10,000 or more
Culpability
intentional
Repeat case
yes
Published
11 May 2023

Original amount 62,173,803 USD, converted at the ECB reference rate of 11 May 2023.

Sources

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