Compliance Radar
Who was sanctioned, and for what?
Fines, court rulings and incidents from Europe and North America: 756 cases from 32 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 action- Fine €1bn 99 % · 17 cases
- Disgorgement of profits €5.09m 1 % · 2 cases
- Custodial sentence €143,988 0 % · 3 cases
Who?
by sectorAll sectors
- Defence and security €350.2m 35 % · 3 cases
- Energy and utilities €233.8m 23 % · 3 cases
- Steel and metals €164.7m 16 % · 2 cases
- Telecoms, IT and software €102.6m 10 % · 2 cases
- Transport, logistics and shipping €53.5m 5 % · 1 case
- Construction and real estate €39.7m 4 % · 2 cases
- Media and online platforms €24.8m 2 % · 1 case
- Other €18.4m 2 % · 1 case
- Food and agriculture €8.91m 1 % · 1 case
- Financial services and insurance €4.04m 0 % · 1 case
- 3 more€4.92m
When?
per quarter, by date of decision| Period | Cases | Total |
|---|---|---|
| Q3 2023 | 1 | €24.8m |
| Q4 2023 | 0 | — |
| Q1 2024 | 1 | €90.5m |
| Q2 2024 | 1 | €143,988 |
| Q3 2024 | 1 | €138.9m |
| Q4 2024 | 3 | €393.5m |
| Q1 2025 | 2 | €143.9m |
| Q2 2025 | 0 | — |
| Q3 2025 | 3 | €22.4m |
| Q4 2025 | 1 | €102.1m |
| Q1 2026 | 6 | €68.9m |
| Q2 2026 | 1 | €11.6m |
| Q3 2026 | 2 | €8.91m |
22 cases
16 Oct 2024 RTX Corporation (Raytheon Company)RTX (Raytheon) pays around 391 million USD for bribing a Qatari military official €338.4m
From 2011 to 2017, Raytheon paid almost 2 million USD via sham subcontracts to Qatari military and other public officials and more than 30 million USD to an agent from the ruling family. SEC order: disgorgement of 37,400,090 USD, interest of 11,786,208 USD and a penalty of 75 million USD (of which 22.5 million USD was credited against the DOJ payment); under the DPA with the DOJ, 267,096,068 USD (230.4 million penalty, 36,696,068 forfeiture) is attributable to the FCPA part, combined with an Arms Export Control Act violation and a three-year monitorship. Total without double counting: 368,782,366 USD.
Subcontracts without verifiable services are a classic vehicle for bribes – defence exporters must also disclose payment flows to export control authorities.
Sham subcontracts and agents in defence transactions
- 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, Sections 30A, 13(b)(2)(A)/(B) Exchange Act); Arms Export Control Act; DPA
- Action
- Fine
- Status of proceedings
- final
- Sector
- Defence and security
- Employees
- 10,000 or more
- Culpability
- intentional
- Published
- 16 Oct 2024
Original amount 368,782,366 USD, converted at the ECB reference rate of 16 Oct 2024.
- SEC Order In the Matter of RTX Corporation, Release No. 101353 (16.10.2024) Decision of an authority
- SEC Enforcement Actions: FCPA Cases Enforcement database of an authority
- DOJ Criminal Division: U.S. v. Raytheon Company, Docket No. 24-CR-399 (RER) Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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23 Sep 2026 BGH upholds conviction of a procurement head of unit at the OLG Jena for accepting benefits Custodial sentence
A head of unit at the Higher Regional Court of Jena (OLG Jena) responsible for budget, procurement and personnel of the Thuringian judiciary obtained fourteen loans (375 to 10,000 EUR) from two co-defendants between 2013 and 2019, coupled with the tacit expectation that he would take them into account when awarding contracts; he also concluded service contracts in breach of public procurement law (damage exceeding 450,000 EUR). The Regional Court of Gera (LG Gera) imposed an aggregate suspended prison sentence of two years and confiscation. Germany's Federal Court of Justice (Bundesgerichtshof, BGH) upheld the conviction for accepting benefits (Vorteilsannahme, not Bestechlichkeit, i.e. taking bribes) in 13 cases, discontinued one time-barred case and set aside the aggregate sentence and the amount of the daily fine rate; the defendant's appeal on points of law will be decided separately.
Private loans from suppliers to procurement officers are a criminal offence even without a specific quid pro quo – contracting authorities need clear rules and staff rotation.
Loans and benefits from contractors to procurement officers
- Authority / court
- Bundesgerichtshof (2. Strafsenat); Vorinstanz Landgericht Gera
- Area of law
- Bribery and corruption · Bribery of public officials
- Legal basis
- § 331 StGB (Vorteilsannahme), § 266 StGB (Untreue); BGH 2 StR 554/25
- Action
- Custodial sentence
- Status of proceedings
- under appeal
- Sector
- Public sector
- Culpability
- intentional
- Liability of senior managers
- The former head of unit (a management function in the judicial administration) was convicted; two lenders were co-defendants.
- Published
- 23 Sep 2026
Checked against the official source on 25 Sep 2026 · Direct link
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17 Jul 2026 The Scoular CompanyAgricultural trader Scoular pays 10 million USD over bribes to Mexican border officials €8.91m
From 2013 to 2019, Scoular had customs brokers pay around 400,000 USD to Mexican border and inspection officials so that trains carrying contaminated maize and grain would pass inspections; some of the money went to individuals close to cartels. Three-year DPA with a criminal penalty of 9,769,521 USD and forfeiture of 414,351 USD.
Customs agents and freight forwarders are high-risk third parties: question conspicuous flat fees per shipment, even if they appear to be customary charges.
Facilitation payments via customs agents and logistics service providers
Missing or inadequate training played a role in the decision.
- Authority / court
- U.S. Department of Justice (Criminal Division, Fraud Section; USAO Western District of Texas)
- Area of law
- Bribery and corruption · Bribery of public officials
- Legal basis
- FCPA (Verschwörung zur Verletzung der Anti-Bestechungsvorschriften); Deferred Prosecution Agreement
- Action
- Fine
- Status of proceedings
- final
- Sector
- Food and agriculture
- Culpability
- intentional
- Mitigating circumstances
- Cooperation and remediation (including an overhaul of compliance, third-party management, financial controls and anti-corruption training); 25 % reduction off the low end of the sentencing guidelines range.
- Liability of senior managers
- The customs broker Carlos Leopoldo Alvelais has pleaded guilty.
- Published
- 17 Jul 2026
Original amount 10,183,872 USD, converted at the ECB reference rate of 17 Jul 2026.
- Agricultural Company to Pay Over $10M to Resolve Foreign Bribery Case Press release of an authority
- Deferred Prosecution Agreement, United States v. The Scoular Company, 3:26-cr-01685-KC (W.D. Tex.), filed 07/17/26 Decision of an authority
- DOJ Criminal Division: United States v. The Scoular Company (Fallseite) Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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1 May 2026 Ultra Electronics Holdings Limited (vormals plc)Ultra Electronics: DPA of around 10.1 million GBP over bribery in Algeria and Oman €11.6m
The British defence supplier failed to prevent bribery by agents in connection with three public contracts in Oman and Algeria (including a contract with the Omani Ministry of Transport worth up to 200 million GBP). The DPA approved by Southwark Crown Court provides for a penalty of 10,083,150 GBP; in addition, the company is bearing around 4.8 million GBP of the SFO's investigation costs and must report on its compliance programme for three years.
Companies that use agents for government contracts must be able to demonstrate adequate procedures – otherwise the company is liable under Section 7 Bribery Act even without any intent to bribe on its own part.
Use of sales agents in public contracts
- Authority / court
- Serious Fraud Office (SFO)
- Area of law
- Bribery and corruption · Bribery of public officials
- Legal basis
- Section 7 Bribery Act 2010 (Failure to prevent bribery); Deferred Prosecution Agreement
- Action
- Fine
- Status of proceedings
- final
- Sector
- Defence and security
- Culpability
- intentional
- Mitigating circumstances
- Self-report of the Algerian matters in 2018; restructuring of ownership and leadership; 45 % discount on the penalty.
- Published
- 1 May 2026
Original amount 10,083,150 GBP, converted at the ECB reference rate of 30 Apr 2026.
- SFO secures £10m from British defence supplier Press release of an authority
- SFO DPA with Ultra Electronics Holdings Limited (formerly plc) Decision of an authority
- Serious Fraud Office v Ultra Electronics Holdings [2026] EWCR 4 (Approved Judgment, 1 May 2026) Court decision
- SFO-Ultra Indictment (Crown Court at Southwark) Decision of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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19 Mar 2026 Colas Rail Asia Sdn Bhd (Colas-Gruppe)Colas Rail Asia: CJIP of 29.7 million EUR over bribery in metro contracts in Malaysia €29.7m
The Malaysian subsidiary of Colas Rail paid large, undocumented sums via intermediaries in connection with public contracts for urban rail lines in Kuala Lumpur (Kelana Jaya extension, MRT2). Following an internal investigation, Colas Rail self-reported the matter in 2017; the CJIP (Convention judiciaire d'intérêt public, a French deferred prosecution agreement) provides for a public interest fine of 29,745,974 EUR and a three-year compliance programme monitored by the French Anti-Corruption Agency (AFA) (costs of up to 1.9 million EUR).
Undocumented payments to intermediaries on foreign projects must be stopped early by the finance and compliance functions – self-reporting after an internal investigation is rewarded.
Intermediaries and consultants in public tenders
- 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
- Action
- Fine
- Status of proceedings
- final
- Sector
- Construction and real estate
- Employees
- 10,000 or more
- Culpability
- intentional
- Mitigating circumstances
- Self-report (criminal complaint filed by Colas Rail on 31 May 2017) following an internal forensic investigation.
- Liability of senior managers
- The CJIP does not address the criminal liability of natural persons.
- Published
- 19 Mar 2026
- Communiqué de presse du procureur de la République financier – CJIP COLAS RAIL ASIA Press release of an authority
- Convention judiciaire d'intérêt public – COLAS RAIL ASIA (17.03.2026) 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
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19 Mar 2026 Balt USA LLC (Balt-Gruppe)Balt USA: CJIP in France over payments to a hospital physician €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 offences committed by a former manager of the acquired company Blockade Medical.
Acquisitions require anti-corruption due diligence on the target company – otherwise legacy misconduct by its management becomes a group risk.
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
- Communiqué de presse du procureur de la République financier – CJIP BALT USA Press release of an authority
- Ministère de la Justice – Conventions judiciaires d'intérêt public (Liste) Official register or notice
- CJIP Société BALT USA LLC (17.03.2026) Decision of an authority
Checked against the official source on 25 Sep 2026 · 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 €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.
Physicians at public hospitals are public officials – consultancy agreements with them require documented services and approval by the compliance function.
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
- A former manager of the US subsidiary (David Ferrera) and a consultant (Marc Tilman) were charged with FCPA violations and money laundering.
- Published
- 19 Mar 2026
Original amount 1,214,797 USD, converted at the ECB reference rate of 17 Mar 2026.
- Justice Department Resolves Foreign Bribery Investigation with Balt SAS; Healthcare Executive and Sales Consultant Indicted Press release of an authority
- Communiqué de presse du procureur de la République financier – CJIP BALT USA (19.03.2026) Press release of an authority
- DOJ Criminal Division, Fraud Section: Declination Letter Re: Balt SAS (17.03.2026) Decision of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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6 Mar 2026 Fleurette Properties LtdCommodities holding Fleurette: 25.8 million EUR strafbeschikking over bribery in Congo €25.8m
According to the Dutch Public Prosecution Service (OM), the top holding company of a mining, oil and gold group, which was based in the Netherlands from 2010 to 2017, participated together with others in bribing public officials of the DR Congo in order to obtain licences for cobalt and copper mines. On 6 March 2026, the OM issued a strafbeschikking (prosecutorial penalty order) imposing a fine of 25.8 million EUR, which Fleurette accepted.
In the commodities sector, licences and concessions are the main target for bribery – holding companies share liability for payments made by their subsidiaries.
Award of licences in the commodities sector, payments to public officials
- Authority / court
- Openbaar Ministerie (OM); Ermittlungen FIOD Anti-Corruptie Centrum
- Area of law
- Bribery and corruption · Bribery of public officials
- Legal basis
- Buitenlandse ambtelijke omkoping (Wetboek van Strafrecht); OM-strafbeschikking
- Action
- Fine
- Status of proceedings
- final
- Sector
- Steel and metals
- Culpability
- intentional
- Published
- 10 Mar 2026
- Geldboete Fleurette Properties Ltd wegens omkoping in Congo Press release of an authority
Checked against the official source on 25 Sep 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 the head of state-owned PMU Mali €499,150
From 2008 to 2011, the Paris-based supplier of betting and gaming terminals made unjustified payments of 78,972 EUR to the head of the majority state-owned Pari Mutuel Urbain 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 25 Sep 2026 · Direct link
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10 Feb 2026 Strukton Civiel Projecten B.V. und Strukton International B.V. (Strukton-Gruppe)Construction group Strukton pays 10 million EUR out-of-court settlement over bribery on the Riyadh Metro €10m
To secure a share in the Riyadh Metro project, around 31 million USD was paid between 2013 and 2021 to an agent representing a high-ranking member of the Saudi royal family; the agent payments were understated to the export credit insurer Atradius. Strukton accepted a transaction (out-of-court settlement) of 10 million EUR.
Commissions to agents with ties to ruling families carry the highest risk – and false statements to export credit insurers constitute a second offence.
Agent commissions and false statements to export credit insurers
- Authority / court
- Openbaar Ministerie (OM)
- Area of law
- Bribery and corruption · Bribery of public officials
- Legal basis
- Buitenlandse ambtelijke omkoping und valsheid in geschrift (Wetboek van Strafrecht); Transactie nach Art. 74 Sr
- Action
- Fine
- Status of proceedings
- final
- Sector
- Construction and real estate
- Culpability
- intentional
- Mitigating circumstances
- Cooperation from mid-2023; compliance programme in place since 2017; the employees involved are no longer with the company.
- Liability of senior managers
- The Dutch Public Prosecution Service (OM) is considering prosecuting several natural persons involved (not named).
- Published
- 30 Mar 2026
- Strukton betaalt hoge transactie van 10 miljoen euro na corruptieonderzoek Press release of an authority
- OM Functioneel Parket: Transactieovereenkomst Calisto (10.02.2026) Decision of an authority
- College van procureurs-generaal: Beslissing hoge transactie onderzoek Calisto (09.02.2026) Decision of an authority
Checked against the official source on 25 Sep 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).
- Liability of senior managers
- According to the DOJ, the scheme was directed by the then Guatemalan shareholder and other senior individuals; four individuals had already been charged (not named).
- 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 25 Sep 2026 · Direct link
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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
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7 Aug 2025 Liberty Mutual Insurance CompanyLiberty Mutual: declination against 4.7 million USD after bribery of Indian state bank employees €4.04m
From 2017 to 2022, the Indian subsidiary Liberty General Insurance paid around 1.47 million USD to employees of six state-owned banks so that they would refer bank customers to its insurance products; the payments were booked as marketing expenses and routed through third parties. The DOJ declined to prosecute; Liberty Mutual is disgorging 4,699,088 USD in profits.
Employees of state-owned banks are public officials – sales commissions paid to them are bribes, even if they are booked as marketing.
Distribution partnerships with state-owned banks, payments disguised as marketing
- Authority / court
- U.S. Department of Justice (Fraud Section; USAO District of Massachusetts)
- Area of law
- Bribery and corruption · Bribery of public officials
- Legal basis
- FCPA, 15 U.S.C. § 78dd-2; Corporate Enforcement and Voluntary Self-Disclosure Policy (Declination)
- Action
- Disgorgement of profits
- Status of proceedings
- final
- Sector
- Financial services and insurance
- Employees
- 10,000 or more
- Culpability
- intentional
- Mitigating circumstances
- Voluntary self-disclosure (March 2024), full cooperation, root cause analysis, termination of those involved, improved controls including rules on messaging apps.
- Published
- 7 Aug 2025
Original amount 4,699,088 USD, converted at the ECB reference rate of 7 Aug 2025.
- DOJ Declination Letter – Liberty Mutual Insurance Company (07.08.2025) Decision of an authority
- DOJ Criminal Division: CEP Declinations Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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6 Aug 2025 LG Neuruppin/BGH: 3.5 years' imprisonment for bribing the head of a state-owned waste management company Custodial sentence
From 2015 to 2019, the managing director of a supplier of landfill technology granted the managing director of a waste management company controlled by two German federal states benefits of around 696,325 EUR and in return received preferential contracts. Because the waste management company is state-controlled, its head was deemed a public official. The prison sentence of 3 years and 6 months is final; the confiscation of 1,982,658.63 EUR must be decided afresh.
Anyone supplying municipal or state-owned companies is, in legal terms, bribing public officials – the stricter Sections 331 et seq. StGB (German Criminal Code) apply there, not merely Section 299 StGB.
Managing directors of public companies as public officials
- Authority / court
- Bundesgerichtshof (6. Strafsenat); Vorinstanz Landgericht Neuruppin
- Area of law
- Bribery and corruption · Bribery of public officials
- Legal basis
- § 334 StGB (Bestechung) i. V. m. § 11 Abs. 1 Nr. 2 c StGB; BGH 6 StR 315/24; LG Neuruppin 13 KLs 26/23
- Action
- Custodial sentence
- Status of proceedings
- final
- Sector
- Energy and utilities
- Culpability
- intentional
- Liability of senior managers
- The supplier's managing director was sentenced to 3 years and 6 months' imprisonment.
- Published
- 5 Jan 2026
Checked against the official source on 25 Sep 2026 · Direct link
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11 Feb 2025 KLUBB France SASVehicle body builder KLUBB France: CJIP over an ambulance contract in Algeria €558,024
Following a referral from the public prosecutor's office in Rennes, the PNF investigated bribery of foreign public officials in the performance of a contract for the supply of ambulances to Algeria. KLUBB France is paying a public interest fine of 558,024 EUR and is undergoing a three-year AFA compliance programme.
Medium-sized exporters are also in the spotlight: companies supplying foreign authorities need a robust anti-corruption programme under Sapin II (the French anti-corruption law).
Export contracts with state bodies
- 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
- Action
- Fine
- Status of proceedings
- final
- Sector
- Manufacturing and mechanical engineering
- Employees
- 50 to 249
- Culpability
- intentional
- Liability of senior managers
- The CJIP does not address the criminal liability of natural persons.
- Published
- 11 Feb 2025
- Communiqué de presse du procureur de la République financier – CJIP KLUBB France Press release of an authority
- CJIP KLUBB France SAS (10.02.2025) Decision of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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31 Jan 2025 Trafigura Beheer B.V.Swiss Federal Criminal Court (Bundesstrafgericht) convicts Trafigura of bribery in Angola €143.3m
Between 2009 and 2011, more than 4 million EUR and more than 600,000 USD were paid to a senior employee of the Angolan state oil distributor in order to promote ship chartering and bunkering business of the Trafigura group. The court convicted the then parent company for lacking rules on the supervision of intermediaries, imposing a fine of 3 million CHF and a compensatory claim (Ersatzforderung) of 145,634,268 USD (amount converted at the ECB rate of 31 January 2025: 148,933,982 USD in total); three individuals received prison sentences. It was the first judgment of the Federal Criminal Court on corporate criminal liability for foreign bribery; it is not final.
In Switzerland, companies are liable if their organisation fails to prevent bribery – and the compensatory claim can exceed the fine many times over.
Payments via intermediaries to employees of state-owned oil companies
- Authority / court
- Bundesstrafgericht (Strafkammer); Anklage durch die Bundesanwaltschaft
- Area of law
- Bribery and corruption · Bribery of public officials
- Legal basis
- Art. 102 StGB i. V. m. Art. 322septies StGB (Bestechung fremder Amtsträger); SK.2023.49
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Energy and utilities
- Employees
- 10,000 or more
- Culpability
- intentional
- Liability of senior managers
- A former senior manager of the group received a prison sentence of 32 months (12 of them unsuspended), the intermediary 24 months suspended, and the Angolan public official 36 months (names anonymised).
- Published
- 31 Jan 2025
Original amount 148,933,982 USD, converted at the ECB reference rate of 31 Jan 2025.
- Bundesstrafgericht: Verurteilung einer juristischen und drei natürlicher Personen wegen Bestechung fremder Amtsträger (SK.2023.49) Court press release
- TRAFIGURA BEHEER BV und drei natürliche Personen vor Bundesstrafgericht angeklagt Press release of an authority
- Bundesstrafgericht, Dispositiv SK.2023.49 vom 31.01.2025 Court decision
Checked against the official source on 25 Sep 2026 · Direct link
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19 Dec 2024 AAR Corp.Aviation services provider AAR pays 55.6 million USD for bribery in Nepal and South Africa €53.5m
Through an agent and a joint venture partner, AAR paid sham commissions to public officials 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.
- Liability of senior managers
- A former senior employee of an AAR subsidiary, Deepak Sharma (named in the SEC order), was involved.
- 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 25 Sep 2026 · Direct link
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11 Oct 2024 Moog Inc.Moog: SEC order over bribery of Indian public officials by a subsidiary €1.54m
From 2020 to 2022, employees of the Indian subsidiary of the aerospace and defence supplier bribed Indian public officials via agents and distributors, among other things to tailor tenders in Moog's favour; the payments were booked as business expenses. Payment of 504,926 USD in disgorgement, 78,889 USD in interest and a penalty of 1.1 million USD.
Even small foreign subsidiaries need effective controls over payments to distributors and agents – otherwise the listed parent company is liable under the books-and-records provisions.
Influencing tender conditions via distributors
- 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 (Sections 13(b)(2)(A)/(B) Exchange Act)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Manufacturing and mechanical engineering
- Culpability
- intentional
- Mitigating circumstances
- Cooperation (sharing of internal investigation findings) and remediation, including termination of employees and third parties.
- Published
- 11 Oct 2024
Original amount 1,683,815 USD, converted at the ECB reference rate of 11 Oct 2024.
- SEC Order In the Matter of Moog Inc., Release No. 101307 (11.10.2024) Decision of an authority
- SEC Enforcement Actions: FCPA Cases Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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5 Aug 2024 Glencore International AGOffice of the Attorney General of Switzerland: summary penalty order against Glencore over bribery in Congo €138.9m
Glencore failed to take all reasonable organisational precautions to prevent the bribery of foreign public officials by a business partner in connection with the acquisition of minority stakes in two mining companies in the DR Congo in 2011. The Office of the Attorney General of Switzerland (Bundesanwaltschaft, BA) issued a summary penalty order (Strafbefehl) imposing a fine of 2 million CHF and a compensatory claim of 150 million USD (amount converted at the ECB rate of 5 August 2024: 152,357,266 USD in total); further matters from 2007–2017 were discontinued.
Companies are also liable for bribery by business partners if they have not taken adequate due diligence and control measures.
Corruption risks posed by business partners in acquisitions of stakes
- Authority / court
- Bundesanwaltschaft (BA)
- Area of law
- Bribery and corruption · Bribery of public officials
- Legal basis
- Art. 102 Abs. 2 StGB (Unternehmensverantwortlichkeit) i. V. m. Bestechung fremder Amtsträger; Strafbefehl
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Steel and metals
- Employees
- 10,000 or more
- Culpability
- intentional
- Published
- 5 Aug 2024
Original amount 152,357,266 USD, converted at the ECB reference rate of 5 Aug 2024.
- Bundesanwaltschaft schliesst Strafuntersuchung gegen Glencore International AG mit Strafbefehl und Einstellungsverfügung ab Press release of an authority
- OM: Geldboete Fleurette Properties Ltd wegens omkoping in Congo (erwähnt Strafbefehl gegen Glencore vom 05.08.2024) Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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12 Apr 2024 Former MoD official jailed for 30 months – bribes from consultants €143,988
A British Ministry of Defence official seconded to a defence contractor accepted more than 70,000 GBP (44,000 GBP in cash and two cars) in return for commissioning work from offshore consultants. He was convicted of misconduct in public office and sentenced to 30 months' imprisonment, with a confiscation order of 123,000 GBP; the associated company GPT had already pleaded guilty in 2021.
Kickbacks for consultancy contracts expose public servants and suppliers alike – contract awards require a four-eyes principle and conflict-of-interest declarations.
Kickbacks in the engagement of consultants
- Authority / court
- Serious Fraud Office (SFO)
- Area of law
- Bribery and corruption · Bribery of public officials
- Legal basis
- Misconduct in public office (Common Law); Proceeds of Crime Act (Confiscation)
- Action
- Custodial sentence
- Status of proceedings
- unknown
- Sector
- Defence and security
- Culpability
- intentional
- Liability of senior managers
- The former MoD official Jeffrey Cook was personally sentenced to imprisonment.
- Published
- 12 Apr 2024
Original amount 123,000 GBP, converted at the ECB reference rate of 12 Apr 2024.
- Former MoD official jailed for taking £70k in kickbacks Press release of an authority
- SFO: Former MoD official convicted for taking £70k in secret kickbacks (6 March 2024) Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link