Compliance Radar
Who was sanctioned, and for what?
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.
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per quarter, by date of decision| Period | Cases | Total |
|---|---|---|
| Q4 2023 | 0 | – |
| Q1 2024 | 0 | – |
| Q2 2024 | 0 | – |
| Q3 2024 | 0 | – |
| Q4 2024 | 0 | – |
| Q1 2025 | 0 | – |
| Q2 2025 | 1 | €3.44m |
| Q3 2025 | 0 | – |
| Q4 2025 | 0 | – |
| Q1 2026 | 0 | – |
| Q2 2026 | 0 | – |
| Q3 2026 | 0 | – |
| Q4 2026 | 0 | – |
1 case
5 May 2025 Minerva S.A.Minerva: BRL 22m fine under leniency agreement over advantages for public officials €3.44m
Minerva S.A. acknowledged, in a leniency agreement with the CGU and the AGU, that it had paid economic advantages to public officials whose action or omission was in the company's interest. The full fine under Art. 6 I Lei 12.846/2013 of BRL 51,376,161.22 was reduced by 57.1% to BRL 22,040,373.16 (indexed to IPCA up to March 2025) and is allegedly payable to the Union. The amount and the facts have not been confirmed against the primary source.
A working compliance programme and early cooperation noticeably reduce the fine, but do not cancel out the effect of management responsibility.
Payments to public officials to influence official action
- 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. 6 I, Arts. 16 und 17; Lei 8.429/1992, Art. 12; Decreto 11.129/2022
- Action
- Fine
- Status of proceedings
- final
- Sector
- Food and agriculture
- Mitigating circumstances
- Credit was given for returning the advantage (1%), cooperation (1%), voluntary admission (1.5%) and an applied compliance programme (2.1%).
- Liability of senior managers
- Tolerance or knowledge by management (3%) and the concurrence of several offences (3%) were aggravating factors.
Original amount 22,040,373.16 BRL, converted at the ECB reference rate of 5 May 2025.
- CGU/AGU – Acordo de Leniência com a Minerva S.A. (Processo 00190.102672/2022-82) Decision of an authority
- Acordo de Leniência Minerva – Anexo II: Demonstrativo de cálculo e valor da multa Decision of an authority
- Acordo de Leniência Minerva – Anexo III: Demonstrativo do valor, imputação e instrução para pagamento Decision of an authority
- CGU – Acordos de leniência celebrados (Liste) Official register or notice
Checked against the official source on 3 Oct 2026 · Direct link