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.
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Where?
by regionAll jurisdictions
What for?
by topic- Bribery of public officials €210.6m 91 % · 5 cases
- Commercial bribery €16.1m 7 % · 1 case
- no topic €4.93m 2 % · 2 cases
Who?
by company- Comunicaciones Celulares S.A. (TIGO Guatemala) €102.1m 44 % · 1 case
- Telefónica Venezolana C.A. €79.1m 34 % · 1 case
- Anonymised companies €28.9m 12 % · 2 cases
- Exclusive Networks Corporate SAS €16.1m 7 % · 1 case
- Linkcon Ltda. €3.43m 1 % · 1 case
- RSX Informática Ltda. €1.49m 1 % · 1 case
- Périphériques et Matériels de Contrôle SAS (Groupe Carrus) €499,150 0 % · 1 case
When?
per year, by date of decision| Period | Cases | Total |
|---|---|---|
| 2022 | 1 | €23.8m |
| 2023 | 1 | €5.11m |
| 2024 | 1 | €79.1m |
| 2025 | 2 | €118.2m |
| 2026 | 3 | €5.42m |
8 cases
9 Jul 2026 RSX Informática Ltda.RSX Informática: BRL 8.8m and three-year debarment for procurement fraud €1.49m
The Controladoria-Geral da União (CGU, Office of the Comptroller General) imposed on RSX Informática Ltda. a fine of BRL 8,794,574.67, extraordinary publication of the decision and a three-year ban on tendering for and contracting with the Federal Union, including removal from the supplier register SICAF. The case concerned fraud in a tender (pregão nº 5/2017) of the former Ministry of National Integration and in the resulting contracts; through the price registration agreement, other federal bodies, including the social security institute INSS with a software contract, contracted with the company without holding their own tender.
Price registration agreements carry the effects of a rigged tender into many public bodies, so the award must be clean from the outset.
Integrity in tenders and framework agreements
- Authority / court
- Controladoria-Geral da União (CGU)
- Area of law
- Bribery and corruption
- Legal basis
- Lei nº 12.846/2013, Art. 5 IV d, Art. 6 I und II; Lei nº 10.520/2002, Art. 7
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Telecoms, IT and software
- Published
- 10 Jul 2026
Original amount 8,794,574.67 BRL, converted at the ECB reference rate of 9 Jul 2026.
- DOU Seção 1 Nr. 128 vom 10.07.2026 (Faksimile, CGU Base de Conhecimento): Decisão nº 202 de 9.7.2026, PAR 00190.106958/2025-80 Decision of an authority
- CGU: Relatório Final, PAR 00190.106958/2025-80 (RSX Informática) Decision of an authority
- Base de Conhecimento CGU: PAR 00190.106958/2025-80 (RSX Informática) Official register or notice
Checked against the official source on 3 Oct 2026 · Direct link
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18 Feb 2026 Périphériques et Matériels de Contrôle SAS (Groupe Carrus)Betting terminal manufacturer PMC: CJIP over payments to an official in Mali €499,150
From 2008 to 2011, the Paris-based supplier of betting and gaming terminals made unjustified payments of 78,972 EUR to an official of a majority state-owned company in Mali, with which it had a supply contract awarded without a tender. The case was triggered by a report from TRACFIN (the French financial intelligence unit). Public interest fine of 499,150 EUR (including 335,000 EUR already seized) and a three-year AFA compliance programme.
Managers of state-controlled companies are also public officials – even small private payments to them create a risk of criminal liability for medium-sized companies.
Payments to heads of state-owned companies abroad
- 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 und Geldwäsche
- Action
- Fine
- Status of proceedings
- final
- Sector
- Telecoms, IT and software
- Employees
- 50 to 249
- Culpability
- intentional
- Liability of senior managers
- The CJIP does not address the criminal liability of natural persons.
- Published
- 18 Feb 2026
- Communiqué de presse du procureur de la République financier – CJIP PMC Press release of an authority
- Convention judiciaire d'intérêt public – Périphériques et Matériels de Contrôle SAS Decision of an authority
- Ministère de la Justice: Conventions judiciaires d'intérêt public (Verzeichnis) Official register or notice
Checked against the official source on 28 Sep 2026 · Version 2 · Direct link
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9 Jan 2026 Linkcon Ltda.Linkcon: BRL 21.5m and debarment over a rigged port authority tender €3.43m
The Controladoria-Geral da União (CGU, Office of the Comptroller General) imposed on Linkcon Ltda. a fine of BRL 21,521,878.64, extraordinary publication of the decision and a two-year ban on tendering for and contracting with the Federal Union. According to the final report, an electronic tender of the port company Companhia Docas do Rio de Janeiro (PE 17/2016) and the resulting price registration agreement were steered in the company's favour through simulated price surveys; it also submitted a false document to be classified as a small business (EPP). The CGU rejected the request for reconsideration on 30 July 2026. The amount and the facts have not been confirmed against the primary source.
Price surveys and proof of company size in public procurement must be genuine; manipulation leads to heavy fines and debarment.
Fair competition and truthful evidence 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 a, Art. 6 I und II; Lei nº 10.520/2002, Art. 7
- Action
- Fine
- Status of proceedings
- final
- Sector
- Telecoms, IT and software
- Published
- 12 Jan 2026
Original amount 21,521,878.64 BRL, converted at the ECB reference rate of 9 Jan 2026.
- DOU Seção 1 vom 12.01.2026, S. 113: CGU Decisão nº 6 de 9.1.2026 (Linkcon Ltda.) Decision of an authority
- DOU Seção 1 vom 03.08.2026 (Faksimile, CGU Base de Conhecimento): Decisão nº 240 de 30.7.2026, Reconsideração abgelehnt Decision of an authority
- CGU: Relatório Final, PAR 00190.109659/2024-16 (Linkcon) Decision of an authority
Checked against the official source on 3 Oct 2026 · Direct link
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12 Nov 2025 Comunicaciones Celulares S.A. (TIGO Guatemala)TIGO Guatemala pays more than 118 million USD for bribing members of Congress €102.1m
From 2012 to 2018, the Guatemalan mobile network operator made monthly cash payments to members of Congress or their security staff in order to obtain legislative support; part of the funds came from laundered drug money. Two-year Deferred Prosecution Agreement with a criminal penalty of 60 million USD and administrative forfeiture of 58,198,343 USD.
In joint ventures with local partners, the parent company needs genuine control over cash flows and contacts with public officials – an early voluntary self-disclosure is no substitute for a full investigation.
Bribery of public officials, cash payments, integrity of co-shareholders
- Authority / court
- U.S. Department of Justice (Criminal Division, Fraud Section; USAO Southern District of Florida)
- Area of law
- Bribery and corruption · Bribery of public officials
- Legal basis
- FCPA, 15 U.S.C. § 78dd-3 (Verschwörung, 18 U.S.C. § 371); Deferred Prosecution Agreement
- Action
- Fine
- Status of proceedings
- final
- Sector
- Telecoms, IT and software
- Culpability
- intentional
- Mitigating circumstances
- Voluntary self-disclosure by the parent company Millicom in 2015; subsequently extensive cooperation and remediation (including dismissals of staff and an 800 % increase in compliance personnel).
- Published
- 12 Dec 2025
Original amount 118,198,343 USD, converted at the ECB reference rate of 12 Nov 2025.
- TIGO Guatemala Paid Over $118M to Resolve Foreign Bribery Investigation Press release of an authority
- Deferred Prosecution Agreement, United States v. Comunicaciones Celulares S.A. d/b/a TIGO Guatemala (Case 1:25-cr-20476) Decision of an authority
Checked against the official source on 28 Sep 2026 · Version 2 · Direct link
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19 Jun 2025 Exclusive Networks Corporate SASIT distributor Exclusive Networks: CJIP of 16 million EUR following a whistleblower report €16.1m
In 2021, a whistleblower reported payments by subsidiaries in Indonesia, Malaysia, Vietnam, Thailand and India to contractual partners; the investigation concerned private-sector bribery and bribery of foreign public officials. The CJIP provides for a public interest fine of 16,074,511 EUR (including 1 million EUR already seized) and a three-year AFA compliance programme.
A functioning whistleblowing system uncovers foreign risks – companies should investigate reports themselves before the authorities do.
Payments to sales partners in Asia, whistleblowing systems
- Authority / court
- Parquet national financier (PNF); Validierung durch das Tribunal judiciaire de Paris
- Area of law
- Bribery and corruption · Commercial bribery
- Legal basis
- Art. 41-1-2 Code de procédure pénale (CJIP); Bestechung im privaten Sektor und ausländischer Amtsträger
- Action
- Fine
- Status of proceedings
- final
- Sector
- Telecoms, IT and software
- Employees
- 1,000 to 9,999
- Culpability
- intentional
- Liability of senior managers
- The CJIP does not address the criminal liability of natural persons.
- Published
- 19 Jun 2025
- Communiqué de presse du procureur de la République financier – CJIP Exclusive Networks Corporate Press release of an authority
- CJIP société Exclusive Networks Corporate (16.06.2025) Decision of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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8 Nov 2024 Telefónica Venezolana C.A.Telefónica Venezolana: USD 85.26m for bribery in a state currency auction €79.1m
The Venezuelan subsidiary of Spain's Telefónica S.A. entered into a DPA and pays a penalty of USD 85,260,000. To be allowed to exchange bolívares for US dollars in a state currency auction in 2014, it had two suppliers pay about USD 28.9 million to an intermediary, part of which went to Venezuelan officials, and covered the cost through overpriced equipment purchases from those suppliers. It received more than USD 110 million from the auction, over 65% of the funds awarded. The authority allegedly made the findings set out here; this account is not based on a final judgment.
Purchases with conspicuous price mark-ups can fund bribery – pricing anomalies must be part of every compliance review.
Inflated purchase prices with suppliers as a hidden channel for bribes
- 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
- final
- Sector
- Telecoms, IT and software
- Mitigating circumstances
- Cooperation (initially diminished by late production of records) and remediation were credited: disciplinary action including dismissals, an independent compliance function with a Chief Compliance Officer, review of all non-standard pricing transactions, tighter third-party controls; 20% reduction.
- Published
- 8 Nov 2024
Original amount 85,260,000 USD, converted at the ECB reference rate of 8 Nov 2024.
- Telefónica Venezolana to Pay Over $85M to Resolve Foreign Bribery Investigation (DOJ, 08.11.2024) Press release of an authority
- Telefónica Venezolana To Pay Over $85 Million To Resolve Foreign Bribery Investigation (USAO SDNY, 08.11.2024) Press release of an authority
Checked against the official source on 3 Oct 2026 · Direct link
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4 Dec 2023 a Brazilian IT companyIT company: BRL 27.2m leniency agreement over bribery and irregular bookkeeping €5.11m
A Brazilian IT company acknowledged to the CGU and the AGU that it had booked funds irregularly in order to pay undue advantages to public officials or politicians and had thereby obtained advantages in contracts with the public administration (Art. 5 I–IV Lei 12.846/2013). The total debt of BRL 27,178,868.56 comprises compensation to an injured company (BRL 4,875,501.13) and to the health fund of the State of Santa Catarina (BRL 17,587,259.86) plus an anti-corruption fine of BRL 4,716,107.57. Because earlier agreements with the Federal Public Prosecutor's Office and the state comptroller CGE/SC are credited, only the fine payable to the Union remains outstanding.
Irregular bookkeeping used to fund bribes creates liability in itself – clean accounting is corruption prevention.
Concealed bookkeeping to fund bribes
- 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–IV, Arts. 16 und 17; Lei 8.429/1992; Decreto 11.129/2022
- Action
- Disgorgement of profits
- Status of proceedings
- final
- Sector
- Telecoms, IT and software
- Mitigating circumstances
- Credit was given for restitution or compensation (1%), cooperation (1.5%), voluntary admission (2%) and an applied compliance programme (2.4%).
- Liability of senior managers
- Tolerance by senior management was applied as an aggravating factor at 3%.
Original amount 27,178,868.56 BRL, converted at the ECB reference rate of 4 Dec 2023.
Checked against the official source on 7 Oct 2026 · Company name anonymised since 4 Dec 2025 · Direct link
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27 Sep 2022 a major US software groupSEC: US software group pays 22.9 million USD – slush funds for bribery and conference trips of officials €23.8m
According to the order of the Securities and Exchange Commission (SEC, the US securities regulator), subsidiaries in Turkey, the United Arab Emirates and India created off-book slush funds from 2016 to 2019, which were used to bribe foreign officials; in Turkey and the UAE they also financed conference trips for officials, in Turkey partly with family members or side trips to California. The group pays 7,114,376 USD in disgorgement, 791,040 USD in interest and a 15 million USD penalty (together 22,905,417 USD); it is already the second SEC proceeding, following a 2012 settlement over side funds in India.
Require approval, a clear business purpose and proper booking for invitations of officials – conference trips for officials and their families are classic benefits.
Travel and event invitations for officials; discount and partner funds
- Authority / court
- U.S. Securities and Exchange Commission (SEC)
- Area of law
- Bribery and corruption · Bribery of public officials
- Legal basis
- Foreign Corrupt Practices Act (Antibestechungs-, Buchführungs- und interne Kontrollvorschriften)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Telecoms, IT and software
- Employees
- 10,000 or more
- Repeat case
- yes
- Published
- 27 Sep 2022
Original amount 22,905,416.64 USD, converted at the ECB reference rate of 27 Sep 2022.
- SEC, Pressemitteilungen (Übersicht) (Entscheidung 2022) Press release of an authority
- SEC, Administrative Proceedings (Übersicht) (Entscheidung 2022) Decision of an authority
Checked against the official source on 28 Sep 2026 · Version 3 · Company name anonymised since 27 Sep 2024 · Direct link