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?
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What for?
by topicWho?
by company- AAR Corp. €53.5m 65 % · 1 case
- Anonymised companies €29m 35 % · 2 cases
When?
per year, by date of decision| Period | Cases | Total |
|---|---|---|
| 2022 | 1 | €2.75m |
| 2023 | 0 | – |
| 2024 | 2 | €79.8m |
| 2025 | 0 | – |
| 2026 | 0 | – |
3 cases
19 Dec 2024 AAR Corp.Aviation services provider AAR pays 55.6 million USD for bribery in Nepal and South Africa €53.5m
According to the SEC's findings, AAR paid sham commissions to public officials through intermediaries (a sales agent and a joint venture partner) in order to secure the sale of two Airbus A330s to Nepal Airlines and maintenance services for South African Airways Technical. SEC: 23,451,100 USD in disgorgement and 5,785,524 USD in interest; DOJ criminal penalty of 26,363,029 USD under a Non-Prosecution Agreement.
State-owned airlines are public contracting entities – scrutinise commissions to intermediaries in aircraft transactions rigorously.
Agents and joint venture partners in transactions with state-owned airlines
- Authority / court
- U.S. Securities and Exchange Commission (SEC); U.S. Department of Justice
- Area of law
- Bribery and corruption · Bribery of public officials
- Legal basis
- FCPA (Anti-Bestechung, Buchführung, interne Kontrollen); Non-Prosecution Agreement
- Action
- Fine
- Status of proceedings
- final
- Sector
- Transport, logistics and shipping
- Employees
- 1,000 to 9,999
- Culpability
- intentional
- Mitigating circumstances
- Disclosure following press reports, cooperation (forensics, translations, witnesses) and remedial measures.
- Published
- 19 Dec 2024
Original amount 55,599,653 USD, converted at the ECB reference rate of 19 Dec 2024.
- SEC Order In the Matter of AAR Corp., Release No. 101987 (19.12.2024) Decision of an authority
- DOJ Criminal Division: Non-Prosecution Agreement Re: AAR Corp. (19.12.2024) Decision of an authority
Checked against the official source on 28 Sep 2026 · Version 4 · Direct link
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13 Jun 2024 three Norwegian shipping companiesThree Norwegian shipping companies: leniency agreement worth BRL 153.2m €26.3m
Three Norwegian shipping companies acknowledged, in a leniency agreement with the CGU and the AGU, that a commission they paid was partly used by third parties to fund bribes to a public official and gave them financial advantages in performing contracts with the public administration. Together they pay BRL 153,184,045.95: BRL 16,055,700.00 in damages and BRL 124,662,133.17 as return of the undue advantage to the injured subsidiary of a state-controlled group, plus a fine of BRL 12,466,212.78 under Lei 8.429/1992 payable to the Union.
Commissions to intermediaries are a classic channel for bribes; if the company benefits, it is liable for how they are used.
Commissions to intermediaries as a channel for 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 8.666/1993, Art. 88 II und III; Lei 8.429/1992, Art. 9 i. V. m. Art. 3; Lei 12.846/2013, Arts. 16 und 17; Decreto 11.129/2022
- Action
- Disgorgement of profits
- Status of proceedings
- final
- Sector
- Transport, logistics and shipping
Original amount 153,184,045.95 BRL, converted at the ECB reference rate of 13 Jun 2024.
Checked against the official source on 7 Oct 2026 · Company name anonymised since 13 Jun 2026 · Direct link
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15 Sep 2022 a Brazilian airlineBrazilian airline: leniency agreement with CGU and AGU for BRL 14.27m €2.75m
An airline entered into a leniency agreement (acordo de leniência) with the Controladoria-Geral da União (CGU, Office of the Comptroller General) and the Advocacia-Geral da União (AGU, Office of the Attorney General) concerning payments to public officials or third parties connected to them, which it had self-reported in 2020. It pays a total of BRL 14,266,602.39, of which BRL 8,559,964.86 is the return of the undue advantages paid and BRL 5,706,637.53 a fine under the Administrative Improbity Law (Lei nº 8.429/1992). The agreement forms part of a coordinated global resolution with the US Department of Justice (DOJ) and the US Securities and Exchange Commission (SEC).
Self-reporting payments to public officials early and cooperating fully can secure a coordinated resolution with reduced sanctions in Brazil and, in parallel, in the United States.
Payments to public officials and connected third parties
- 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 nº 12.846/2013 (Lei Anticorrupção); Lei nº 8.429/1992 (Lei de Improbidade Administrativa)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Transport, logistics and shipping
- Mitigating circumstances
- Self-report in 2020 and effective cooperation, which according to the CGU led to mitigated sanctions; commitment to keep improving its integrity policies and control mechanisms.
- Published
- 15 Sep 2022
Original amount 14,266,602.39 BRL, converted at the ECB reference rate of 15 Sep 2022.
Checked against the official source on 7 Oct 2026 · Company name anonymised since 15 Sep 2024 · Direct link