Compliance Radar

Who was sanctioned, and for what?

Fines, court rulings and incidents from Europe and North America: 718 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.

36cases from 5 jurisdictions
€6.12bnTotal of monetary amounts (35 cases with an amount)
€4.75bnLargest single case: Purdue Pharma L.P.
€11.7mMedian per case with an amount

Click a bar to drill down one level.

When?

per quarter, by date of decision
Trend
PeriodCasesTotal
Q3 20231€24.8m
Q4 20230—
Q1 20241€90.5m
Q2 20241€11.1m
Q3 20244€183.7m
Q4 20243€393.5m
Q1 20252€143.9m
Q2 20252€193.9m
Q3 20252€22.4m
Q4 20252€107.9m
Q1 20267€69.7m
Q2 20265€4.8bn
Q3 20266€80.8m

36 cases

28 Apr 2026 Purdue Pharma L.P.Purdue Pharma: 5.544 billion USD penalty – including kickbacks via the speaker programme USAGifts, hospitality and benefits €4.75bn

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.

What organisations can take from it

Fee programmes for customers who drive revenue can become part of a criminal overall scheme – with consequences that threaten the company’s existence.

Relevance to training and awareness

Speaker fees and benefits for prescribing physicians

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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10 Sep 2026 Dompé U.S. Inc.Dompé U.S.: 32 million USD – Medicare patients’ co-payments covered via foundations USAGifts, hospitality and benefits €27.5m

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.

What organisations can take from it

Benefits flowing to customers via foundations or other third parties remain benefits provided by the company – donations to patient assistance programmes require strict independence.

Relevance to training and awareness

Benefits to patients and customers via third parties

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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10 Aug 2026 Veloxis Pharmaceuticals Inc.Veloxis: over 46 million USD – luxury trips, dinners and gifts for transplant teams USAGifts, hospitality and benefits Other

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.

What organisations can take from it

Invitations and gifts to decision-makers must not only be limited but also fully reported to transparency registers.

Relevance to training and awareness

Gifts, travel and hospitality for healthcare professionals; transparency reporting

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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30 Jul 2026 Access DX Laboratory, LLCAccess DX Laboratory: 36.4 million USD – kickbacks for unnecessary genetic tests USACommercial bribery €31.7m

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.

What organisations can take from it

Commission models for intermediaries who bring in orders or patients are a classic gateway for bribery.

Relevance to training and awareness

Remuneration of intermediaries and referrers

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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20 Jul 2026 NeoGenomics Laboratories Inc.NeoGenomics: 9.8 million USD after self-disclosure – discounted consulting for referring physicians USACommercial bribery €8.59m

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.

What organisations can take from it

Free or discounted services are also benefits – like cash payments, they belong in the anti-corruption review.

Relevance to training and awareness

Services with monetary value provided to customers below market value

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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20 Jul 2026 EyePoint Pharmaceuticals, Inc.EyePoint: 4.66 million USD – kickbacks to surgery centres for purchasing an eye medicine USACommercial bribery €4.08m

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.

What organisations can take from it

Discounts, payments or services to institutions that make purchasing decisions require a documented consideration at market value.

Relevance to training and awareness

Granting benefits to customers and purchasing decision-makers

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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17 Jul 2026 The Scoular CompanyAgricultural trader Scoular pays 10 million USD over bribes to Mexican border officials USABribery of public 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.

What organisations can take from it

Customs agents and freight forwarders are high-risk third parties: question conspicuous flat fees per shipment, even if they appear to be customary charges.

Relevance to training and awareness

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.

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

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17 Jun 2026 Advanced Pathology Solutions PLLC und APS MSO LLCAdvanced Pathology Solutions: 30 million USD for kickbacks and unnecessary laboratory tests USACommercial bribery €25.9m

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.

What organisations can take from it

Where services are sold through referrals, all benefits to referrers belong in a central approval and review procedure.

Relevance to training and awareness

Benefits to clients in healthcare

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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14 May 2026 Takeda Pharmaceuticals U.S.A., Inc.Takeda: 13.7 million USD – speaker fees and luxury meals for prescribing physicians USAGifts, hospitality and benefits €11.7m

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.

What organisations can take from it

Speaker programmes need a demonstrable educational purpose – repeated attendance and expensive hospitality turn them into inducements.

Relevance to training and awareness

Invitations, hospitality and fees for healthcare professionals

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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1 May 2026 Ultra Electronics Holdings Limited (vormals plc)Ultra Electronics: DPA of around 10.1 million GBP over bribery in Algeria and Oman United KingdomBribery of public officials €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.

What organisations can take from it

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.

Relevance to training and awareness

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.

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

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1 May 2026 Modern Nuclear Inc.Modern Nuclear: 8.33 million USD – excessive supervision fees paid to referring cardiologists USACommercial bribery €7.12m

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.

What organisations can take from it

Remuneration of business partners who refer work must correspond to the market value of the service – any overpayment acts as a bribe.

Relevance to training and awareness

Checking fee agreements with referrers for market conformity

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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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 FranceBribery of public officials €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).

What organisations can take from it

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.

Relevance to training and awareness

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

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 FranceBribery of public officials €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.

What organisations can take from it

Acquisitions require anti-corruption due diligence on the target company – otherwise legacy misconduct by its management becomes a group risk.

Relevance to training and awareness

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

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 USABribery of public officials €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.

What organisations can take from it

Physicians at public hospitals are public officials – consultancy agreements with them require documented services and approval by the compliance function.

Relevance to training and awareness

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.

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 NetherlandsBribery of public officials €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.

What organisations can take from it

In the commodities sector, licences and concessions are the main target for bribery – holding companies share liability for payments made by their subsidiaries.

Relevance to training and awareness

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

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

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5 Mar 2026 Allin IP DX LLCAllin IP DX: 980,000 USD after self-disclosure over paid referral marketers USACommercial bribery €843,519

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.

What organisations can take from it

Early self-disclosure limits the damage – but this requires the compliance function to actually get to see problematic sales contracts.

Relevance to training and awareness

Success-based remuneration of sales partners

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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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 FranceBribery of public officials €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.

What organisations can take from it

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.

Relevance to training and awareness

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

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 NetherlandsBribery of public officials €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.

What organisations can take from it

Commissions to agents with ties to ruling families carry the highest risk – and false statements to export credit insurers constitute a second offence.

Relevance to training and awareness

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

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

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22 Dec 2025 New York-Presbyterian Hudson Valley HospitalNYP Hudson Valley Hospital: 6.8 million USD for payments to referring practice USACommercial bribery €5.79m

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.

What organisations can take from it

Cooperation agreements between hospitals and office-based practices must properly document services and remuneration – otherwise payments are treated as referral bonuses.

Relevance to training and awareness

Payments to referrers in hospitals

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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12 Nov 2025 Comunicaciones Celulares S.A. (TIGO Guatemala)TIGO Guatemala pays more than 118 million USD for bribing members of Congress USABribery of public officials €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.

What organisations can take from it

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.

Relevance to training and awareness

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.

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 FranceBribery of public officials €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.

What organisations can take from it

If a state customer insists on an interposed trader without any discernible added value, treat this as a red flag for misappropriation and bribery.

Relevance to training and awareness

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

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 USABribery of public officials €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.

What organisations can take from it

Employees of state-owned banks are public officials – sales commissions paid to them are bribes, even if they are booked as marketing.

Relevance to training and awareness

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.

Checked against the official source on 25 Sep 2026 · 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 FranceCommercial bribery €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.

What organisations can take from it

A functioning whistleblowing system uncovers foreign risks – companies should investigate reports themselves before the authorities do.

Relevance to training and awareness

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

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

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28 Apr 2025 Gilead Sciences, Inc.Gilead: 202 million USD – speaker programmes with fees, luxury meals and travel USAGifts, hospitality and benefits €177.8m

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.

What organisations can take from it

Selecting speakers by prescription volume turns continuing education into bribery – selection criteria and hospitality limits must be documented.

Relevance to training and awareness

Fees and hospitality at professional events

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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11 Feb 2025 KLUBB France SASVehicle body builder KLUBB France: CJIP over an ambulance contract in Algeria FranceBribery of public officials €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.

What organisations can take from it

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).

Relevance to training and awareness

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

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 SwitzerlandBribery of public officials €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.

What organisations can take from it

In Switzerland, companies are liable if their organisation fails to prevent bribery – and the compensatory claim can exceed the fine many times over.

Relevance to training and awareness

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.

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 USABribery of public officials €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.

What organisations can take from it

State-owned airlines are public contracting entities – scrutinise commissions to intermediaries in aircraft transactions rigorously.

Relevance to training and awareness

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.

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

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16 Oct 2024 RTX Corporation (Raytheon Company)RTX (Raytheon) pays around 391 million USD for bribing a Qatari military official USABribery of public officials €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.

What organisations can take from it

Subcontracts without verifiable services are a classic vehicle for bribes – defence exporters must also disclose payment flows to export control authorities.

Relevance to training and awareness

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.

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 USABribery of public officials €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.

What organisations can take from it

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.

Relevance to training and awareness

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.

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

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10 Sep 2024 Deere & CompanyDeere pays 9.9 million USD: Wirtgen Thailand bribed the air force and the highways authority USAGifts, hospitality and benefits €9m

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.

What organisations can take from it

After acquisitions, integrate subsidiaries swiftly into the compliance programme and controls – otherwise old practices such as luxury trips for customers live on.

Relevance to training and awareness

Travel, hospitality and entertainment for public officials

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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5 Aug 2024 Glencore International AGOffice of the Attorney General of Switzerland: summary penalty order against Glencore over bribery in Congo SwitzerlandBribery of public officials €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.

What organisations can take from it

Companies are also liable for bribery by business partners if they have not taken adequate due diligence and control measures.

Relevance to training and awareness

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.

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

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18 Jul 2024 DaVita Inc.DaVita: 34.5 million USD – kickbacks for referrals to dialysis centres and pharmacy USACommercial bribery €31.6m

The dialysis group allegedly paid kickbacks to promote referrals to its former pharmacy subsidiary DaVita Rx and granted benefits to nephrologists and vascular surgeons to induce them to send patients to DaVita dialysis centres. DaVita paid 34,487,390 USD.

What organisations can take from it

Intra-group routing of customers to subsidiaries must not be bought with benefits for third parties.

Relevance to training and awareness

Benefits for referrers

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
Employees
10,000 or more

Original amount 34,487,390 USD, converted at the ECB reference rate of 18 Jul 2024.

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

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1 Jul 2024 Guardian Health Care Inc., Gem City Home Care LLC, Care Connection of Cincinnati LLC und Evolution Health LLCEvolution Health home care providers: 4.5 million USD – kickbacks to senior living facilities and physicians USACommercial bribery €4.18m

Three home health agencies in Texas, Ohio and Indiana and their parent company allegedly granted kickbacks to assisted living facilities and physicians for Medicare referrals. They paid 4,496,330 USD.

What organisations can take from it

Cooperation with facilities that refer customers requires written contracts with remuneration at market rates and regular review.

Relevance to training and awareness

Benefits for cooperation partners who refer customers

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

Original amount 4,496,330 USD, converted at the ECB reference rate of 1 Jul 2024.

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

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29 May 2024 Innovasis Inc.Innovasis: 12 million USD – kickbacks to spine surgeons USACommercial bribery €11.1m

The Utah manufacturer of spinal implants and two executives – founder and president Brent Felix and former CFO Garth Felix – allegedly paid surgeons kickbacks to induce them to use Innovasis products. Together they paid 12 million USD; HHS-OIG placed the company under heightened scrutiny.

What organisations can take from it

Consultancy agreements, royalty payments or fees to users who decide on the use of products require proof of need and a fair market value review.

Relevance to training and awareness

Payments to users of medical devices

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
Founder/president and former CFO pay personally as parties to the settlement.

Original amount 12,000,000 USD, converted at the ECB reference rate of 29 May 2024.

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

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1 Mar 2024 Gunvor SAGunvor convicted: around 86.7 million CHF over corruption in Ecuador's oil business SwitzerlandBribery of public officials €90.5m

The Geneva-based commodities trading house failed to take all reasonable organisational precautions to prevent foreign public officials from being bribed on its behalf in connection with the Ecuadorian oil industry from 2013 to 2017. The Office of the Attorney General of Switzerland (BA) – in coordination with US authorities – ordered Gunvor to pay around 86.7 million CHF, of which 4.3 million CHF is a fine.

What organisations can take from it

Commodities traders must scrutinise payments to intermediaries in government business without gaps – the confiscation of profits far exceeds the fine.

Relevance to training and awareness

Payments via intermediaries to state-owned oil companies

Authority / court
Bundesanwaltschaft (BA)
Area of law
Bribery and corruption · Bribery of public officials
Legal basis
Art. 102 StGB (Unternehmensverantwortlichkeit) i. V. m. Bestechung fremder Amtsträger
Action
Fine
Status of proceedings
unknown
Sector
Energy and utilities
Culpability
intentional
Published
1 Mar 2024

Original amount 86,700,000 CHF, converted at the ECB reference rate of 1 Mar 2024.

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

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28 Sep 2023 Clear Channel Outdoor Holdings Inc.Clear Channel Outdoor: 26.1 million USD – gifts and hospitality for Chinese officials USABribery of public officials €24.8m

From at least 2012 to 2017, the Chinese majority-owned subsidiary Clear Media bribed officials with expensive gifts and hospitality and used sham intermediaries and false invoices to fund concealed consultants in order to obtain advertising space, for example at bus stops; the payments were booked as entertainment, cleaning and customer development expenses. Despite repeated warnings from internal audit, adequate controls were lacking until 2019; Clear Channel paid 16,355,567 USD in disgorgement, 3,760,920 USD in interest and a civil penalty of 6 million USD (a total of 26,116,487 USD).

What organisations can take from it

Internal audit findings on entertainment and consultancy costs in high-risk markets must lead to immediate controls.

Relevance to training and awareness

Gifts and hospitality for public officials; correct booking

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 (Anti-Bribery, Books and Records, Internal Accounting Controls)
Action
Fine
Status of proceedings
final
Sector
Media and online platforms

Original amount 26,116,487 USD, converted at the ECB reference rate of 28 Sep 2023.

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

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