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.
Click a bar to drill down one level.
Where?
by regionAll jurisdictions
What for?
by topicWho?
by companyWhen?
per year, by date of decision| Period | Cases | Total |
|---|---|---|
| 2023 | 1 | €82.1m |
| 2024 | 2 | €126m |
| 2025 | 1 | €18.4m |
| 2026 | 0 | – |
4 cases
3 Sep 2025 SURYS SAS (Gruppe Imprimerie Nationale)Hologram manufacturer SURYS: CJIP of 18.4 million EUR in the Ukrainian passport case €18.4m
From 2013, SURYS supplied security holograms for Ukrainian passports to the state-owned company Polygraph via an interposed Estonian company; the investigation (following a request for mutual legal assistance from Ukraine's National Anti-Corruption Bureau, NABU) concerned misappropriation of public funds, bribery of foreign public officials and money laundering. Public interest fine of 18,363,007 EUR, plus 3,770,000 EUR in damages to the Ukrainian state and a three-year AFA compliance programme.
If a state customer insists on an interposed trader without any discernible added value, treat this as a red flag for misappropriation and bribery.
Interposed trading companies and sales agents
- 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, Geldwäsche
- Action
- Fine
- Status of proceedings
- final
- Sector
- Other
- Employees
- 250 to 999
- Culpability
- intentional
- Liability of senior managers
- The CJIP does not address the criminal liability of natural persons.
- Published
- 3 Sep 2025
- Communiqué de presse du procureur de la République financier – CJIP SURYS Press release of an authority
- Convention judiciaire d'intérêt public – SURYS (08.07.2025) Decision of an authority
- Ministère de la Justice: Conventions judiciaires d'intérêt public (Verzeichnis) Official register or notice
Checked against the official source on 25 Sep 2026 · Direct link
Report an error
5 Dec 2024 McKinsey and Company Africa (Pty) LtdMcKinsey Africa: USD 122.85m for bribery at two South African state-owned companies €116.6m
The South African subsidiary of McKinsey & Company entered into a three-year DPA with a penalty of USD 122,850,000; up to half is credited against payments to South African authorities. According to the Department, between at least 2012 and 2016 it obtained confidential information from two South African state-owned companies (logistics and energy) on consulting contracts and bid knowing that South African partner firms would pass part of their fees on to officials as bribes. According to the Department, the profit from the scheme was about USD 85 million.
Local partner firms in consortia with state-owned enterprises need the same anti-corruption vetting as one's own intermediaries, including how their fees are used.
Local partner firms and consortia as a bribery channel in public-sector consulting contracts
Missing or inadequate training played a role in the decision.
- Authority / court
- U.S. Department of Justice (Criminal Division, Fraud Section; USAO Southern District of New York)
- Area of law
- Bribery and corruption · Bribery of public officials
- Legal basis
- Foreign Corrupt Practices Act (FCPA): Verschwörung zum Verstoß gegen die Anti-Bribery-Vorschriften (Criminal Information, Southern District of New York)
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Other
- Mitigating circumstances
- Credit was given for immediate, proactive cooperation, reporting of discovered attempts to delete records, personnel consequences, additional anti-corruption training in Africa and a temporary halt to work for state-owned enterprises.
- Liability of senior managers
- Measures against individuals are not reported here.
- Published
- 5 Dec 2024
Original amount 122,850,000 USD, converted at the ECB reference rate of 5 Dec 2024.
- McKinsey & Company Africa to Pay Over $122M in Connection with Bribery of South African Government Officials (DOJ, 05.12.2024) Press release of an authority
- McKinsey & Company Africa To Pay Over $120 Million In Connection With Bribery Of South African Government Officials (USAO SDNY, 05.12.2024) Press release of an authority
Checked against the official source on 28 Sep 2026 · Direct link
Report an error
18 Nov 2024 BIT Mining Ltd. (vormals 500.com)BIT Mining (formerly 500.com): USD 10m for bribing Japanese officials €9.48m
The company entered into a three-year DPA; under the guidelines USD 54 million would have been appropriate, but because of a demonstrated inability to pay a penalty of USD 10 million was agreed, of which up to USD 4 million is credited against the SEC civil penalty. From 2017 to 2019 the company, then trading as 500.com, agreed to pay about USD 1.9 million to consultants, intended to reach Japanese officials as cash, travel, entertainment and gifts, in order to win an integrated resort bid in Japan; the payments were booked as consultancy fees under sham contracts. The authority allegedly made the findings set out here; this account is not based on a final judgment.
Anyone bidding for state concessions abroad must check consultancy and intermediary agreements for genuine services and for where the money goes.
Consultancy agreements in foreign licensing and major project tenders
- Authority / court
- U.S. Department of Justice (Criminal Division, Fraud Section; USAO District of New Jersey)
- Area of law
- Bribery and corruption · Bribery of public officials
- Legal basis
- Foreign Corrupt Practices Act (FCPA): Verschwörung zum Verstoß gegen die Anti-Bribery- und Books-and-Records-Vorschriften sowie Verstoß gegen die Books-and-Records-Vorschriften (Criminal Information, District of New Jersey)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Other
- Mitigating circumstances
- The penalty was capped at USD 10 million because of the company's financial condition; limited, reactive cooperation and remediation were credited (10% reduction off the bottom of the guidelines range).
- Liability of senior managers
- Measures against individuals are not set out here.
- Published
- 18 Nov 2024
Original amount 10,000,000 USD, converted at the ECB reference rate of 18 Nov 2024.
Checked against the official source on 3 Oct 2026 · Direct link
Report an error
27 Apr 2023 a Swiss security technology providerPenalty order: CHF 81m against security technology provider for bribery in South America €82.1m
Because of deficiencies in corporate governance, risk management and compliance, employees of a Swiss security technology provider were able to bribe public officials in connection with business in Brazil, Colombia and Venezuela. The Bundesanwaltschaft (BA, Office of the Attorney General of Switzerland) convicted the company by summary penalty order and imposed a fine of CHF 1,000,000 and a compensatory claim of CHF 80,000,000, CHF 81 million in total. The penalty order against the company is final because the company waived its right to object.
Anyone selling to state bodies in high-risk markets needs effective sales controls, or a large compensatory claim will follow the fine.
Bribery of foreign public officials in sales; compliance organisation
- Authority / court
- Bundesanwaltschaft (BA)
- Area of law
- Bribery and corruption · Bribery of public officials
- Legal basis
- Art. 102 Abs. 2 StGB i.V.m. Art. 322septies StGB; Ersatzforderung nach Art. 71 Abs. 1 StGB
- Action
- Fine
- Status of proceedings
- final
- Sector
- Other
- Published
- 27 Apr 2023
Original amount 81,000,000 CHF, converted at the ECB reference rate of 27 Apr 2023.
- Bundesanwaltschaft, Medienmitteilungen (Übersicht) (Entscheidung 2023) Press release of an authority
Checked against the official source on 2 Oct 2026 · Company name anonymised since 27 Apr 2025 · Direct link