Compliance Radar
Who was sanctioned, and for what?
Fines, court rulings and incidents from Europe, North America, Latin America, Asia-Pacific, Middle East and Africa: 2,207 cases from 44 jurisdictions, each with an official source and checked against that source before publication. Filter by country, area of law and sector. Click a chart to drill down one level.
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Where?
by regionAll jurisdictions
What for?
by topicWho?
by sectorAll sectors
- Chemicals and pharmaceuticals €5.14bn 64 % · 10 cases
- Energy and utilities €864.9m 11 % · 7 cases
- Manufacturing and mechanical engineering €390.4m 5 % · 9 cases
- Defence and security €357.3m 4 % · 3 cases
- Healthcare €246.2m 3 % · 18 cases
- Telecoms, IT and software €231.6m 3 % · 8 cases
- Other €226.5m 3 % · 4 cases
- Steel and metals €164.7m 2 % · 2 cases
- Food and agriculture €122.6m 2 % · 6 cases
- Financial services and insurance €108.9m 1 % · 6 cases
- 5 more€193m
When?
per year, by date of decision| Period | Cases | Total |
|---|---|---|
| 2022 | 9 | €805.1m |
| 2023 | 12 | €431.2m |
| 2024 | 20 | €958.3m |
| 2025 | 20 | €873.8m |
| 2026 | 25 | €4.98bn |
86 cases
28 Apr 2026 Purdue Pharma L.P.Purdue Pharma: 5.544 billion USD penalty – including kickbacks via the speaker programme €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.
Fee programmes for customers who drive revenue can become part of a criminal overall scheme – with consequences that threaten the company’s existence.
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.
- HHS-OIG Enforcement Actions: Opioid Manufacturer Purdue Pharma Sentenced for Fraud and Kickback Conspiracies (28.04.2026) Enforcement database of an authority
- U.S. Department of Justice: Opioid Manufacturer Purdue Pharma Sentenced for Fraud and Kickback Conspiracies (28.04.2026) Press release of an authority
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 €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.
Benefits flowing to customers via foundations or other third parties remain benefits provided by the company – donations to patient assistance programmes require strict independence.
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.
- HHS-OIG Enforcement Actions: Dompé U.S. Agrees to Pay $32M to Resolve False Claims Act Liability Relating to Self-Disclosure of Patient Kickbacks (10.09.2026) Enforcement database of an authority
- U.S. Department of Justice: Dompé U.S. Agrees to Pay $32M to Resolve False Claims Act Liability Relating to Self-Disclosure of Patient Kickbacks (10.09.2026) Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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10 Sep 2026 Southern Glazer’s Wine and Spirits, LLCSouthern Glazer’s: USD 12.5m over benefits to retailer employees €10.8m
The nationwide wine and spirits distributor headquartered in Florida entered into a non-prosecution agreement and pays USD 12.5 million. It admitted that executives and employees had for years provided employees of alcohol retailers, including grocery chains in California, with cash, prepaid gift cards, flights, golf trips, resort stays and luxury goods to influence the purchase and placement of its products, concealing this through third-party vendors and false invoices. The authority allegedly made the findings set out here; this account is not based on a final judgment.
Benefits to customers' employees are commercial bribery – marketing budgets run through third-party vendors need document and recipient checks.
Benefits to buyers and employees of trade customers; concealment through third-party vendors and false invoices
- Authority / court
- U.S. Attorney's Office, Northern District of California (U.S. Department of Justice)
- Area of law
- Bribery and corruption · Commercial bribery
- Action
- Other
- Status of proceedings
- final
- Sector
- Retail and e-commerce
- Liability of senior managers
- According to the announcement, several California-based executives, including vice presidents, were directly involved.
- Published
- 10 Sep 2026
Original amount 12,500,000 USD, converted at the ECB reference rate of 10 Sep 2026.
Checked against the official source on 3 Oct 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 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.
Invitations and gifts to decision-makers must not only be limited but also fully reported to transparency registers.
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
- DOJ: Veloxis Pharmaceuticals Agrees to Pay Over $46M to Resolve Criminal and Civil Liability for Kickback Schemes (10.08.2026) Press release of an authority
- HHS-OIG Enforcement Actions: Veloxis Pharmaceuticals Agrees to Pay Over $46M … (10.08.2026) Enforcement database of an authority
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 €31.7m
The Houston laboratory allegedly paid kickbacks and billed Medicare and Medicaid for medically unnecessary genetic tests. The settlements with the laboratory and other parties add up to 36.4 million USD (combined total); the laboratory is subject to a Corporate Integrity Agreement.
Commission models for intermediaries who bring in orders or patients are a classic gateway for bribery.
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
- Measures against individuals are not reported here.
Original amount 36,400,000 USD, converted at the ECB reference rate of 30 Jul 2026.
- HHS-OIG Enforcement Actions: Vergleiche mit Access DX Laboratory und weiteren Beteiligten (30.07.2026) Enforcement database of an authority
Checked against the official source on 28 Sep 2026 · Version 3 · Direct link
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23 Jul 2026 Arla Foods Ingredientes Comércio de Produtos Alimentícios Unipessoal Ltda.Arla Foods Ingredientes: leniency agreement after self-report for BRL 31,056.36 €5,375
Arla Foods Ingredientes Comércio de Produtos Alimentícios Unipessoal Ltda. entered into a leniency agreement with the Controladoria-Geral da União (CGU, Office of the Comptroller General) and the Advocacia-Geral da União (AGU, Office of the Attorney General) concerning violations of the Anti-Corruption Law described in an unpublished annex; it had been the first to come forward, in October 2022. The alleged fine of BRL 31,056.36 derives from a preliminary fine of BRL 93,150.45, based on 2021 gross revenue of BRL 6,210,029.68, reduced by 66.66% for self-reporting, degree of cooperation and payment terms.
Self-reporting, full cooperation and the payment terms can together cut a fine under Brazil's Anti-Corruption Law by two thirds in a leniency agreement.
Self-reporting and cooperation where corruption is suspected
- Authority / court
- Controladoria-Geral da União (CGU) und Advocacia-Geral da União (AGU)
- Area of law
- Bribery and corruption
- Legal basis
- Lei nº 12.846/2013, Art. 16 und 17; Decreto nº 11.129/2022, Art. 22, 23 und 47; Lei nº 8.429/1992
- Action
- Fine
- Status of proceedings
- final
- Sector
- Food and agriculture
- Mitigating circumstances
- Total reduction of 66.66% (22.22% each for self-reporting, degree of cooperation and payment terms); compensation for losses, cooperation and voluntary admission also counted as mitigating factors in the calculation.
- Liability of senior managers
- As an aggravating factor, the CGU found that management tolerated or was aware of the acts (3% uplift).
Original amount 31,056.36 BRL, converted at the ECB reference rate of 23 Jul 2026.
- Acordo de Leniência CGU/AGU – Arla Foods Ingredientes Comércio de Produtos Alimentícios Unipessoal Ltda. (Processo 00190.108116/2022-10, SEI 4123003) Decision of an authority
- Acordo de Leniência Arla – Anexo II: Demonstrativo de cálculo do valor da multa (SEI 4123008) Decision of an authority
- CGU: Acordos de leniência celebrados (Liste mit Unternehmen und Beträgen) Official register or notice
Checked against the official source on 3 Oct 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 €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.
Free or discounted services are also benefits – like cash payments, they belong in the anti-corruption review.
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.
- HHS-OIG Enforcement Actions: Florida Laboratory Agrees to Pay $9.8M … Self-Disclosure of Compensation Arrangements (20.07.2026) Enforcement database of an authority
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 €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.
Discounts, payments or services to institutions that make purchasing decisions require a documented consideration at market value.
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.
- HHS-OIG Enforcement Actions: EyePoint Pharmaceuticals to Pay $4.6 Million to Resolve False Claims Act Allegations (20.07.2026) Enforcement database of an authority
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
- Measures against individuals are not reported here.
- 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 28 Sep 2026 · Version 3 · Direct link
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9 Jul 2026 RSX Informática Ltda.RSX Informática: BRL 8.8m and three-year debarment for procurement fraud €1.49m
The Controladoria-Geral da União (CGU, Office of the Comptroller General) imposed on RSX Informática Ltda. a fine of BRL 8,794,574.67, extraordinary publication of the decision and a three-year ban on tendering for and contracting with the Federal Union, including removal from the supplier register SICAF. The case concerned fraud in a tender (pregão nº 5/2017) of the former Ministry of National Integration and in the resulting contracts; through the price registration agreement, other federal bodies, including the social security institute INSS with a software contract, contracted with the company without holding their own tender.
Price registration agreements carry the effects of a rigged tender into many public bodies, so the award must be clean from the outset.
Integrity in tenders and framework agreements
- Authority / court
- Controladoria-Geral da União (CGU)
- Area of law
- Bribery and corruption
- Legal basis
- Lei nº 12.846/2013, Art. 5 IV d, Art. 6 I und II; Lei nº 10.520/2002, Art. 7
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Telecoms, IT and software
- Published
- 10 Jul 2026
Original amount 8,794,574.67 BRL, converted at the ECB reference rate of 9 Jul 2026.
- DOU Seção 1 Nr. 128 vom 10.07.2026 (Faksimile, CGU Base de Conhecimento): Decisão nº 202 de 9.7.2026, PAR 00190.106958/2025-80 Decision of an authority
- CGU: Relatório Final, PAR 00190.106958/2025-80 (RSX Informática) Decision of an authority
- Base de Conhecimento CGU: PAR 00190.106958/2025-80 (RSX Informática) Official register or notice
Checked against the official source on 3 Oct 2026 · Direct link
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2 Jul 2026 IRB-Brasil Resseguros S.A.IRB-Brasil Resseguros: BRL 6.32m settlement over obstructing SUSEP supervision €1.07m
IRB-Brasil Resseguros S.A. concluded a Termo de Compromisso (settlement in sanction proceedings) with the CGU and allegedly pays a fine of BRL 6,317,473.41 because the company had hindered the investigative and supervisory activity of the insurance supervisor SUSEP (Art. 5 V Lei 12.846/2013). The fine equals the statutory minimum of 0.1% of gross revenue (BRL 6,509,921.81) less BRL 192,448.40 already paid in SUSEP proceedings over inconsistent reporting. Extraordinary publication was waived, and the proceedings are thereby closed.
Incomplete or inconsistent information given to a supervisory authority can, as obstruction of supervision, trigger an anti-corruption fine.
Obstructing supervisory authorities through inaccurate information
- Authority / court
- Controladoria-Geral da União (CGU)
- Area of law
- Bribery and corruption
- Legal basis
- Lei 12.846/2013, Art. 5 V, Art. 6 I; Decreto 11.129/2022, Art. 25 § 2; Portaria Normativa CGU 155/2024
- Action
- Fine
- Status of proceedings
- final
- Sector
- Financial services and insurance
- Repeat case
- no
- Mitigating circumstances
- Credit was given for a compliance programme (3.6%), the absence of proof of advantage or damage (1%) and settlement-related reductions for cooperation and admission; fines already paid to SUSEP were deducted.
- Published
- 3 Jul 2026
Original amount 6,317,473.41 BRL, converted at the ECB reference rate of 2 Jul 2026.
- CGU Base de Conhecimento – PAR 00190.102081/2025-58 (IRB-Brasil Resseguros S.A.) Enforcement database of an authority
- CGU – Termo de Compromisso com IRB-Brasil Resseguros S.A. (SEI 4136663) Decision of an authority
- CGU – Nota Técnica nº 1857/2026/CGIST/DIREP/SIPRI (Termo de Compromisso IRB) Decision of an authority
- DOU Seção 3, 3.7.2026 – Extrato de Compromisso CGU/IRB-Brasil Resseguros Official register or notice
Checked against the official source on 3 Oct 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 €25.9m
The Arkansas pathology laboratory and its management company allegedly granted unlawful kickbacks and ordered medically unnecessary tests. The settlement of 30 million USD is a joint payment by all settling parties; the laboratory entered into a Corporate Integrity Agreement.
Where services are sold through referrals, all benefits to referrers belong in a central approval and review procedure.
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
- Measures against individuals are not reported here.
Original amount 30,000,000 USD, converted at the ECB reference rate of 17 Jun 2026.
- HHS-OIG Enforcement Actions: Vergleich mit Advanced Pathology Solutions (17.06.2026) Enforcement database of an authority
Checked against the official source on 28 Sep 2026 · Version 3 · 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 €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.
Speaker programmes need a demonstrable educational purpose – repeated attendance and expensive hospitality turn them into inducements.
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.
- DOJ: Takeda Agrees to Pay $13.6M to Resolve False Claims Allegations Relating to Improper Payments (14.05.2026) Press release of an authority
- HHS-OIG Enforcement Actions: Takeda Agrees to Pay $13.6M … Improper Payments to Physicians (14.05.2026) 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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1 May 2026 Modern Nuclear Inc.Modern Nuclear: 8.33 million USD – excessive supervision fees paid to referring cardiologists €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.
Remuneration of business partners who refer work must correspond to the market value of the service – any overpayment acts as a bribe.
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.
- HHS-OIG Enforcement Actions: Mobile PET Scan Provider to Pay $8.33 Million … Unlawful Kickbacks to Medical Practices (01.05.2026) Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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24 Apr 2026 Colônia dos Pescadores Z-12 do Médio Rio DoceFishers' colony Z-12: BRL 7.18m CGU fine over fraud involving Renova compensation €1.23m
The CGU imposed on the Colônia dos Pescadores Z-12 do Médio Rio Doce a fine of BRL 7,180,921.47 and extraordinary publication of the decision. Acting together with others, the association had falsified its members' applications for entry in the fishing register (RGP) and backdated records and had interfered with the federal fisheries office in Espírito Santo, so that false data found their way into official documents and compensation from the Fundação Renova, together with lawyers' fees, was paid out without entitlement (Art. 5 II, III and V Lei 12.846/2013).
Falsified documents submitted to authorities to obtain compensation
- Authority / court
- Controladoria-Geral da União (CGU)
- Area of law
- Bribery and corruption
- Legal basis
- Lei 12.846/2013, Art. 5 II, III und V, Art. 6 I und II, Art. 14; Decreto 11.129/2022, Arts. 19, 22 und 23
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Food and agriculture
- Liability of senior managers
- Measures against individuals are not set out here.
- Published
- 5 May 2026
Original amount 7,180,921.47 BRL, converted at the ECB reference rate of 24 Apr 2026.
- CGU – Decisão nº 91, de 24 de abril de 2026 (DOU Seção 1, 5.5.2026) Decision of an authority
- CGU Base de Conhecimento – PAR 00190.104175/2024-81 (Colônia dos Pescadores Z-12 do Médio Rio Doce) Enforcement database of an authority
- CGU – Relatório Final da Comissão de PAR, Colônia Rio Doce Decision of an authority
Checked against the official source on 3 Oct 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 conduct at 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 28 Sep 2026 · Version 2 · 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
- Measures against individuals are not reported here.
- Published
- 19 Mar 2026
Original amount 1,214,797 USD, converted at the ECB reference rate of 17 Mar 2026.
- U.S. Department of Justice, Pressemitteilung zu Balt SAS (Entscheidung 2026) 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 28 Sep 2026 · Version 3 · 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