Who was sanctioned, and for what?

Following its 2020 guilty plea, the opioid manufacturer was sentenced in Newark to a criminal fine of 3.544 billion USD (asserted in the insolvency proceedings) and forfeiture of 2 billion USD; up to 1.775 billion USD can be credited against the forfeiture if Purdue emerges from insolvency as a public benefit company. Purdue had deceived the DEA and paid kickbacks to prescribers via its speaker programme and to an electronic health records platform in order to increase opioid prescriptions.

Authority / court

U.S. District Court, District of New Jersey (Anklage: U.S. Department of Justice)

Area of law

Bribery and corruption · Gifts, hospitality and benefits

Legal basis

Verschwörung zum Betrug der USA und zur Verletzung des Food, Drug, and Cosmetic Act; zwei Fälle Verschwörung zur Verletzung des Anti-Kickback Statute (Schuldbekenntnis vom 24.11.2020)

Action

Fine

Status of proceedings

unknown

Sector

Chemicals and pharmaceuticals

Culpability

intentional

Original amount 5,544,000,000 USD, converted at the ECB reference rate of 28 Apr 2026.

Checked against the official source on 25 Sep 2026 · Direct link

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From 2018 to 2021, the pharmaceutical manufacturer allegedly used two patient assistance foundations to fund Medicare beneficiaries’ co-payments for its drug Oxervate in order to promote its sales. Following a self-disclosure, Dompé paid 32 million USD.

Authority / court

U.S. Department of Justice / U.S. Attorney's Office, District of Massachusetts

Area of law

Bribery and corruption · Gifts, hospitality and benefits

Legal basis

Anti-Kickback Statute (42 U.S.C. § 1320a-7b(b)); False Claims Act (31 U.S.C. §§ 3729 ff.)

Action

Other

Status of proceedings

final

Sector

Chemicals and pharmaceuticals

Mitigating circumstances

Self-disclosure.

Original amount 32,000,000 USD, converted at the ECB reference rate of 10 Sep 2026.

Checked against the official source on 25 Sep 2026 · Direct link

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From 2016 to 2023, Veloxis provided transplant professionals with expensive meals and alcohol, trips and stays at luxury resorts, gifts and consultancy fees without consideration, and paid specialty pharmacies concealed remuneration in order to promote prescriptions and purchases of the immunosuppressant Envarsus XR. The company entered into a Deferred Prosecution Agreement with a criminal payment of more than 10 million USD, is paying 34.45 million USD under civil law (21,211,251 USD to the federal government, 13,238,749 USD to states) and a penalty of 1.55 million USD under the Sunshine Act (Open Payments) – the highest to date – totalling over 46 million USD.

Authority / court

U.S. Department of Justice / U.S. Attorney's Office, District of Massachusetts

Area of law

Bribery and corruption · Gifts, hospitality and benefits

Legal basis

Anti-Kickback Statute; False Claims Act; Physician Payments Sunshine Act (Open Payments)

Action

Other

Status of proceedings

final

Sector

Chemicals and pharmaceuticals

Checked against the official source on 25 Sep 2026 · Direct link

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The Houston laboratory, its former CEO Michael Stewart and the businessman Harold Shatz allegedly paid kickbacks and billed Medicare and Medicaid for medically unnecessary genetic tests. The three settlements add up to 36.4 million USD; the laboratory is subject to a Corporate Integrity Agreement.

Authority / court

U.S. Department of Justice

Area of law

Bribery and corruption · Commercial bribery

Legal basis

Anti-Kickback Statute (42 U.S.C. § 1320a-7b(b)); False Claims Act (31 U.S.C. §§ 3729 ff.)

Action

Other

Status of proceedings

final

Sector

Healthcare

Liability of senior managers

Former CEO pays under a separate settlement.

Original amount 36,400,000 USD, converted at the ECB reference rate of 30 Jul 2026.

Checked against the official source on 25 Sep 2026 · Direct link

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The Florida laboratory provided referring physicians with consulting services below market value and paid independent consultants referral-based remuneration for recruiting physicians. Following a self-disclosure, NeoGenomics paid 9,813,260 USD.

Authority / court

U.S. Department of Justice

Area of law

Bribery and corruption · Commercial bribery

Legal basis

Anti-Kickback Statute (42 U.S.C. § 1320a-7b(b)); False Claims Act (31 U.S.C. §§ 3729 ff.)

Action

Other

Status of proceedings

final

Sector

Healthcare

Mitigating circumstances

Self-disclosure of the remuneration arrangements.

Original amount 9,813,260 USD, converted at the ECB reference rate of 20 Jul 2026.

Checked against the official source on 25 Sep 2026 · Direct link

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Between January 2019 and March 2023, the pharmaceutical manufacturer allegedly paid kickbacks to ambulatory surgery centres to induce them to purchase and use the injectable drug DEXYCU for cataract surgery. To resolve the False Claims Act allegations, EyePoint paid 4,657,463.18 USD and entered into a Corporate Integrity Agreement with HHS-OIG.

Authority / court

U.S. Department of Justice

Area of law

Bribery and corruption · Commercial bribery

Legal basis

Anti-Kickback Statute (42 U.S.C. § 1320a-7b(b)); False Claims Act (31 U.S.C. §§ 3729 ff.)

Action

Other

Status of proceedings

final

Sector

Chemicals and pharmaceuticals

Original amount 4,657,463.18 USD, converted at the ECB reference rate of 20 Jul 2026.

Checked against the official source on 25 Sep 2026 · Direct link

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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.

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.

Checked against the official source on 25 Sep 2026 · Direct link

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The Arkansas pathology laboratory, its management company and the owners Kevin Hannah, Donell Burkett and Daniel Hunter Pledger allegedly granted unlawful kickbacks and ordered medically unnecessary tests. Together they paid 30 million USD; the laboratory entered into a Corporate Integrity Agreement.

Authority / court

U.S. Department of Justice

Area of law

Bribery and corruption · Commercial bribery

Legal basis

Anti-Kickback Statute (42 U.S.C. § 1320a-7b(b)); False Claims Act (31 U.S.C. §§ 3729 ff.)

Action

Other

Status of proceedings

final

Sector

Healthcare

Liability of senior managers

The owners contribute personally as parties to the settlement.

Original amount 30,000,000 USD, converted at the ECB reference rate of 17 Jun 2026.

Checked against the official source on 25 Sep 2026 · Direct link

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From 2014 to 2020, Takeda allegedly selected physicians specifically for its speaker programme for the antidepressant Trintellix and provided them with fees and meals at expensive restaurants to promote prescriptions; some participants attended the same event several times without any educational benefit. Takeda paid 13,670,921 USD.

Authority / court

U.S. Department of Justice / U.S. Attorney's Office, Eastern District of California

Area of law

Bribery and corruption · Gifts, hospitality and benefits

Legal basis

Anti-Kickback Statute (42 U.S.C. § 1320a-7b(b)); False Claims Act (31 U.S.C. §§ 3729 ff.)

Action

Other

Status of proceedings

final

Sector

Chemicals and pharmaceuticals

Employees

10,000 or more

Original amount 13,670,921 USD, converted at the ECB reference rate of 14 May 2026.

Checked against the official source on 25 Sep 2026 · Direct link

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The Californian provider of mobile PET scans allegedly paid referring cardiologists excessive fees for supervising the examinations in order to secure referrals. The settlement of 8,334,350.71 USD plus revenue-based payments is based on ability to pay; in addition, there is a Corporate Integrity Agreement.

Authority / court

U.S. Department of Justice / U.S. Attorney's Office, Central District of California

Area of law

Bribery and corruption · Commercial bribery

Legal basis

Anti-Kickback Statute (42 U.S.C. § 1320a-7b(b)); False Claims Act (31 U.S.C. §§ 3729 ff.)

Action

Other

Status of proceedings

final

Sector

Healthcare

Original amount 8,334,350.71 USD, converted at the ECB reference rate of 30 Apr 2026.

Checked against the official source on 25 Sep 2026 · Direct link

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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.

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.

Checked against the official source on 25 Sep 2026 · Direct link

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Between January and June 2023, the Sarasota laboratory paid independent marketers to steer laboratory samples from Medicare beneficiaries to it. It self-disclosed the conduct, cooperated extensively and paid 980,000 USD.

Authority / court

U.S. Attorney's Office, Middle District of Florida

Area of law

Bribery and corruption · Commercial bribery

Legal basis

Anti-Kickback Statute (42 U.S.C. § 1320a-7b(b)); False Claims Act (31 U.S.C. §§ 3729 ff.)

Action

Other

Status of proceedings

final

Sector

Healthcare

Mitigating circumstances

Voluntary self-disclosure, detailed disclosure and cooperation.

Original amount 980,000 USD, converted at the ECB reference rate of 5 Mar 2026.

Checked against the official source on 25 Sep 2026 · Direct link

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The hospital (until 2015 Hudson Valley Hospital Center) allegedly paid an oncology practice in Westchester millions of dollars to induce it to refer patients to the hospital; the hospital billed the services to Medicare and Medicaid. The U.S. Attorney’s Office filed a complaint and at the same time concluded a settlement of 6.8 million USD.

Authority / court

U.S. Attorney's Office, Southern District of New York

Area of law

Bribery and corruption · Commercial bribery

Legal basis

Anti-Kickback Statute (42 U.S.C. § 1320a-7b(b)); False Claims Act (31 U.S.C. §§ 3729 ff.)

Action

Other

Status of proceedings

final

Sector

Healthcare

Original amount 6,800,000 USD, converted at the ECB reference rate of 22 Dec 2025.

Checked against the official source on 25 Sep 2026 · Direct link

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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.

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.

Checked against the official source on 25 Sep 2026 · Direct link

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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.

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.

Checked against the official source on 25 Sep 2026 · Direct link

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Gilead paid physicians who spoke at or attended events on its HIV medicines fees, meals and travel expenses to promote prescriptions; high prescribers received hundreds of thousands of dollars, and events took place at luxury restaurants. The court-approved settlement of 202 million USD contains extensive admissions of fact.

Authority / court

U.S. Attorney's Office, Southern District of New York; U.S. District Court (S.D.N.Y.)

Area of law

Bribery and corruption · Gifts, hospitality and benefits

Legal basis

Anti-Kickback Statute (42 U.S.C. § 1320a-7b(b)); False Claims Act (31 U.S.C. §§ 3729 ff.)

Action

Other

Status of proceedings

final

Sector

Chemicals and pharmaceuticals

Employees

10,000 or more

Published

29 Apr 2025

Original amount 202,000,000 USD, converted at the ECB reference rate of 28 Apr 2025.

Checked against the official source on 25 Sep 2026 · Direct link

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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.

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.

Checked against the official source on 25 Sep 2026 · Direct link

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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.

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.

Checked against the official source on 25 Sep 2026 · Direct link

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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.

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.

Checked against the official source on 25 Sep 2026 · Direct link

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From 2017 to 2020, the acquired subsidiary Wirtgen Thailand provided public officials, including officials of the Royal Thai Air Force and the Department of Highways, with cash, sham consultancy fees, luxurious "factory visit trips", meals and entertainment, and also engaged in commercial bribery. Deere is paying 4,343,401 USD in disgorgement, 1,086,954 USD in interest and a penalty of 4.5 million USD.

Authority / court

U.S. Securities and Exchange Commission (SEC)

Area of law

Bribery and corruption · Gifts, hospitality and benefits

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

Employees

10,000 or more

Culpability

intentional

Liability of senior managers

According to the SEC, senior regional managers who have since left the company were involved (not named).

Published

10 Sep 2024

Original amount 9,930,355 USD, converted at the ECB reference rate of 10 Sep 2024.

Checked against the official source on 25 Sep 2026 · Direct link

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