Compliance Radar

Who was sanctioned, and for what?

Fines, court rulings and incidents from Europe, North America, Latin America, Asia-Pacific and Middle East: 1,929 cases from 40 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.

13cases from 1 jurisdiction
€312.9mTotal of monetary amounts
€4.98mMedian per case with an amount

Click a bar to drill down one level.

Where?

by authority
  1. Controladoria-Geral da União (CGU) und Advocacia-Geral da União (AGU) €216.5m 69 % · 7 cases
  2. Controladoria-Geral da União (CGU) €96.4m 31 % · 6 cases

What for?

by topic
  1. Bribery of public officials €216.5m 69 % · 6 cases
  2. no topic €96.4m 31 % · 7 cases

Who?

by sector

All sectors

  1. Manufacturing and mechanical engineering €113.2m 36 % · 1 case
  2. Financial services and insurance €89.7m 29 % · 3 cases
  3. Energy and utilities €87.7m 28 % · 2 cases
  4. Food and agriculture €9.65m 3 % · 4 cases
  5. Healthcare €7.65m 2 % · 1 case
  6. Telecoms, IT and software €4.93m 2 % · 2 cases

When?

per quarter, by date of decision
Trend
PeriodCasesTotal
Q4 20230–
Q1 20240–
Q2 20240–
Q3 20240–
Q4 20241€17.8m
Q1 20253€84.7m
Q2 20251€3.44m
Q3 20252€194.7m
Q4 20250–
Q1 20262€8.41m
Q2 20261€1.23m
Q3 20263€2.57m
Q4 20260–

13 cases

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 BrazilBribery and corruption €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da União (AGU, Office of the Attorney General) concerning violations of the Anti-Corruption Law described in an unpublished annex; it had been the first to come forward, in October 2022.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.

What organisations can take from it

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.

Relevance to training and awareness

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.

Checked against the official source on 3 Oct 2026 · Direct link

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9 Jul 2026 RSX Informática Ltda.RSX Informática: BRL 8.8m and three-year debarment for procurement fraud BrazilBribery and corruption €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.

What organisations can take from it

Price registration agreements carry the effects of a rigged tender into many public bodies, so the award must be clean from the outset.

Relevance to training and awareness

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.

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 BrazilBribery and corruption €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.

What organisations can take from it

Incomplete or inconsistent information given to a supervisory authority can, as obstruction of supervision, trigger an anti-corruption fine.

Relevance to training and awareness

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.

Checked against the official source on 3 Oct 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 BrazilBribery and corruption €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).

Relevance to training and awareness

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.

Checked against the official source on 3 Oct 2026 · Direct link

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26 Jan 2026 JBJ Agropecuária Ltda., Prima Foods S.A.JBJ Agropecuária and Prima Foods: BRL 31.16m in fines under leniency agreement BrazilBribery of public officials €4.98m

JBJ Agropecuária Ltda. and Prima Foods S.A. acknowledged, in a leniency agreement with the CGU and the AGU, that they had paid an economic advantage to a public official whose action or omission was in their interest (Art. 5 I Lei 12.846/2013). After a 66.6% reduction they allegedly pay fines totalling BRL 31,156,767.70 in three annual instalments and are jointly and severally liable for them. Payments under an agreement on the same facts with the Federal Public Prosecutor's Office (MPF) are credited.

What organisations can take from it

Parallel agreements with prosecutors and oversight bodies can be coordinated – double payments are credited, but the liability remains.

Relevance to training and awareness

Payment to a public official to influence official action

Authority / court
Controladoria-Geral da União (CGU) und Advocacia-Geral da União (AGU)
Area of law
Bribery and corruption · Bribery of public officials
Legal basis
Lei 12.846/2013, Art. 5 I, Art. 6 I, Arts. 16 und 17; Decreto 11.129/2022
Action
Fine
Status of proceedings
final
Sector
Food and agriculture
Mitigating circumstances
For JBJ, credit was given for restitution or compensation (1%), cooperation (1.5%), voluntary admission (2%) and an applied compliance programme (2.5%); overall a 66.6% reduction on the full fine of BRL 93,283,735.64.
Liability of senior managers
For JBJ, tolerance or knowledge by management (3%) and the concurrence of several offences (3%) were aggravating factors.

Original amount 31,156,767.7 BRL, converted at the ECB reference rate of 26 Jan 2026.

Checked against the official source on 3 Oct 2026 · Direct link

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9 Jan 2026 Linkcon Ltda.Linkcon: BRL 21.5m and debarment over a rigged port authority tender BrazilBribery and corruption €3.43m

The Controladoria-Geral da União (CGU, Office of the Comptroller General) imposed on Linkcon Ltda. a fine of BRL 21,521,878.64, extraordinary publication of the decision and a two-year ban on tendering for and contracting with the Federal Union. According to the final report, an electronic tender of the port company Companhia Docas do Rio de Janeiro (PE 17/2016) and the resulting price registration agreement were steered in the company's favour through simulated price surveys; it also submitted a false document to be classified as a small business (EPP). The CGU rejected the request for reconsideration on 30 July 2026. The amount and the facts have not been confirmed against the primary source.

What organisations can take from it

Price surveys and proof of company size in public procurement must be genuine; manipulation leads to heavy fines and debarment.

Relevance to training and awareness

Fair competition and truthful evidence in public procurement

Authority / court
Controladoria-Geral da União (CGU)
Area of law
Bribery and corruption
Legal basis
Lei nº 12.846/2013, Art. 5 IV a, Art. 6 I und II; Lei nº 10.520/2002, Art. 7
Action
Fine
Status of proceedings
final
Sector
Telecoms, IT and software
Published
12 Jan 2026

Original amount 21,521,878.64 BRL, converted at the ECB reference rate of 9 Jan 2026.

Checked against the official source on 3 Oct 2026 · Direct link

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30 Sep 2025 Bulls Holding Investments Company S.A., RS Investimentos S/ABulls Holding and RS Investimentos: BRL 508.8m for obstructing supervision BrazilBribery and corruption €81.5m

The Controladoria-Geral da União (CGU, Office of the Comptroller General) fined Bulls Holding Investments Company S.A. BRL 387,431,733.02 and RS Investimentos S/A BRL 121,380,000.00 (BRL 508,811,733.02 in total) and ordered extraordinary publication of the decision for each. According to the final report, the companies had submitted to the insurance supervisor SUSEP bids to take over the pension association APLUB, which was under special intervention, backed by inadequate and in part apparently forged documents, thereby interfering with SUSEP's supervisory activity; RS Investimentos was additionally sanctioned for supporting Bulls Holding's acts. The amount and the facts have not been confirmed against the primary source.

What organisations can take from it

Misleading documents submitted to a supervisory authority count in Brazil as interference with supervision under the Anti-Corruption Law and can trigger very large fines.

Relevance to training and awareness

Truthful submissions to supervisory authorities

Authority / court
Controladoria-Geral da União (CGU)
Area of law
Bribery and corruption
Legal basis
Lei nº 12.846/2013, Art. 5 II und V, Art. 6 I und II, Art. 14
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Liability of senior managers
Measures against individuals are not set out here.
Published
2 Oct 2025

Original amount 508,811,733.02 BRL, converted at the ECB reference rate of 30 Sep 2025.

Checked against the official source on 3 Oct 2026 · Direct link

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30 Jul 2025 Seatrium Ltd., Jurong Shipyard Pte. Ltd., Estaleiro Jurong Aracruz Ltda.Seatrium and Jurong: leniency agreement for BRL 728.9m BrazilBribery of public officials €113.2m

Seatrium Ltd., Jurong Shipyard Pte. Ltd. (both Singapore) and Estaleiro Jurong Aracruz 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 undue advantages given to public officials or politicials and persons connected to them, and undue advantages obtained in contracts with the public administration. The companies allegedly acknowledged a debt of BRL 728,933,258.58, payable within 60 days; according to the companies, they have also negotiated agreements with the Federal Public Prosecutor's Office (MPF) and Singapore's Attorney-General's Chambers. The amount and the facts have not been confirmed against the primary source.

What organisations can take from it

Companies with large public contracts must effectively prevent benefits to public officials, politicians and their associates, as authorities in several countries act in parallel.

Relevance to training and awareness

Benefits to public officials and politically exposed persons

Authority / court
Controladoria-Geral da União (CGU) und Advocacia-Geral da União (AGU)
Area of law
Bribery and corruption · Bribery of public officials
Legal basis
Lei nº 12.846/2013, Art. 5 I, III und IV d, Art. 16; Lei nº 8.666/1993, Art. 88 II und III; Lei nº 8.429/1992
Action
Fine
Status of proceedings
final
Sector
Manufacturing and mechanical engineering
Mitigating circumstances
Commitment by the CGU and AGU to avoid double payments in relation to an agreement with the MPF; obligation to improve the integrity programme.

Original amount 728,933,258.58 BRL, converted at the ECB reference rate of 30 Jul 2025.

Checked against the official source on 3 Oct 2026 · Direct link

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5 May 2025 Minerva S.A.Minerva: BRL 22m fine under leniency agreement over advantages for public officials BrazilBribery of public officials €3.44m

Minerva S.A. acknowledged, in a leniency agreement with the CGU and the AGU, that it had paid economic advantages to public officials whose action or omission was in the company's interest. The full fine under Art. 6 I Lei 12.846/2013 of BRL 51,376,161.22 was reduced by 57.1% to BRL 22,040,373.16 (indexed to IPCA up to March 2025) and is allegedly payable to the Union. The amount and the facts have not been confirmed against the primary source.

What organisations can take from it

A working compliance programme and early cooperation noticeably reduce the fine, but do not cancel out the effect of management responsibility.

Relevance to training and awareness

Payments to public officials to influence official action

Authority / court
Controladoria-Geral da União (CGU) und Advocacia-Geral da União (AGU)
Area of law
Bribery and corruption · Bribery of public officials
Legal basis
Lei 12.846/2013, Art. 6 I, Arts. 16 und 17; Lei 8.429/1992, Art. 12; Decreto 11.129/2022
Action
Fine
Status of proceedings
final
Sector
Food and agriculture
Mitigating circumstances
Credit was given for returning the advantage (1%), cooperation (1%), voluntary admission (1.5%) and an applied compliance programme (2.1%).
Liability of senior managers
Tolerance or knowledge by management (3%) and the concurrence of several offences (3%) were aggravating factors.

Original amount 22,040,373.16 BRL, converted at the ECB reference rate of 5 May 2025.

Checked against the official source on 3 Oct 2026 · Direct link

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28 Mar 2025 Trafigura Beheer B.V.Trafigura Beheer: leniency agreement with CGU and AGU for BRL 435.4m BrazilBribery of public officials €69.9m

Trafigura Beheer B.V. 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) in which it admitted paying undue advantages to public officials and using front persons to conceal its interests. It allegedly pays BRL 435,410,672.26: BRL 153,710,689.11 within ten days (the conversion of USD 26,829,346; under its agreement with the US Department of Justice on a fine of USD 80,488,040, this part of the US fine may be offset by the payment to the Brazilian authorities) and BRL 281,699,983.15 (the conversion of USD 49,169,165.53) as the remaining balance. The amount and the facts have not been confirmed against the primary source.

What organisations can take from it

In corruption cases involving several countries, double payments can be avoided through coordinated agreements with all the authorities involved.

Relevance to training and awareness

Payments to public officials and use of intermediaries

Authority / court
Controladoria-Geral da União (CGU) und Advocacia-Geral da União (AGU)
Area of law
Bribery and corruption · Bribery of public officials
Legal basis
Lei nº 12.846/2013, Art. 5 I und III, Art. 16; Lei nº 8.429/1992; Decreto nº 11.129/2022
Action
Fine
Status of proceedings
final
Sector
Energy and utilities
Mitigating circumstances
Coordination with the US proceedings so that part of the Brazilian payment can be credited against the US fine; obligation to improve the integrity programme under CGU monitoring for 36 months.

Original amount 435,410,672.26 BRL, converted at the ECB reference rate of 28 Mar 2025.

Checked against the official source on 3 Oct 2026 · Direct link

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17 Mar 2025 Qualicorp Consultoria e Corretora de Seguros S.A.Qualicorp: leniency agreement worth BRL 44.5m over payment to a public official BrazilBribery of public officials €7.15m

Qualicorp Consultoria e Corretora de Seguros S.A. acknowledged, in a leniency agreement with the CGU and the AGU, that it had paid an economic advantage to a public official whose action or omission was in the company's interest. It allegedly pays BRL 44,485,434.29 as a fine plus disgorgement: BRL 27,803,396.43 as disgorgement of the advantage obtained and a fine of BRL 16,682,037.86 under Lei 12.846/2013 (40% reduction), both indexed to IPCA up to December 2024. The agreement extends to other companies of the Qualicorp group. The amount and the facts have not been confirmed against the primary source.

What organisations can take from it

If management knows of or tolerates payments to officials, the fine rises; without an effective compliance programme there is also no mitigating factor.

Relevance to training and awareness

Payment to a public official to influence official action

Authority / court
Controladoria-Geral da União (CGU) und Advocacia-Geral da União (AGU)
Area of law
Bribery and corruption · Bribery of public officials
Legal basis
Lei 12.846/2013, Art. 6 I, Arts. 16 und 17, Art. 19 I; Lei 8.429/1992; Decreto 11.129/2022
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Credit was given for returning the advantage (1%), cooperation (1.5%) and voluntary admission (2%); no compliance programme was taken into account. The fine equals the statutory minimum of the advantage obtained, then reduced by 40%.
Liability of senior managers
Tolerance or knowledge by senior management was applied as an aggravating factor at the maximum rate of 3%.

Original amount 44,485,434.29 BRL, converted at the ECB reference rate of 17 Mar 2025.

Checked against the official source on 3 Oct 2026 · Direct link

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23 Jan 2025 Associação da Irmandade da Santa Casa de Misericórdia de PacaembuSanta Casa de Pacaembu: BRL 47.4m for fraud in hospital management contracts BrazilBribery and corruption €7.65m

The Controladoria-Geral da União (CGU, Office of the Comptroller General) imposed on the Associação da Irmandade da Santa Casa de Misericórdia de Pacaembu, an association operating as a healthcare social organisation (Organização Social), a fine of BRL 47,391,386.87, extraordinary publication of the decision and a declaration of unsuitability for public contracts. According to the final report, the association rigged the selection procedure for managing the Hangar field hospital in Belém (Pará), committed fraud in performing the management contract for a regional hospital in Belém and used front persons and companies to conceal its real interests.

What organisations can take from it

Associations that run hospitals on behalf of the state are also liable under the Anti-Corruption Law, and their leaders can be held personally liable.

Relevance to training and awareness

Integrity in selection procedures and management contracts in healthcare

Authority / court
Controladoria-Geral da União (CGU)
Area of law
Bribery and corruption
Legal basis
Lei nº 12.846/2013, Art. 5 III und IV b und d, Art. 6, Art. 14; Lei nº 8.666/1993, Art. 87 IV und Art. 88 II und III
Action
Fine
Status of proceedings
final
Sector
Healthcare
Liability of senior managers
Measures against individuals are not set out here.
Published
28 Jan 2025

Original amount 47,391,386.87 BRL, converted at the ECB reference rate of 23 Jan 2025.

Checked against the official source on 3 Oct 2026 · Direct link

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14 Nov 2024 Freepoint Commodities LLCFreepoint Commodities: leniency agreement worth BRL 131.25m over bribery BrazilBribery of public officials €17.8m

The US company Freepoint Commodities LLC admitted, in a leniency agreement with the CGU and the AGU, to having paid undue advantages to public officials through intermediaries (Art. 5 I and III Lei 12.846/2013) and allegedly pays BRL 108,710,739.68 as a fine plus disgorgement. According to Annex III, BRL 60,919,037.14 is the fine payable to the Union (after a 67% reduction) and BRL 47,791,702.54 is disgorgement. Damages to Petrobras of BRL 22,542,907.62 are set out only in the text. The agreement also stated a total of BRL 131,253,647.32 (USD 22,744,839.85); the two centavos by which that total exceeds the fine, the disgorgement and the damages are not smoothed. If the company resumes business in Brazil within five years, it must adapt its compliance programme to Brazilian law and report to the CGU. The amount and the facts have not been confirmed against the primary source.

What organisations can take from it

Companies that win business through intermediaries must control their payments to officials – otherwise the company itself is liable.

Relevance to training and awareness

Bribery of public officials through intermediaries

Authority / court
Controladoria-Geral da União (CGU) und Advocacia-Geral da União (AGU)
Area of law
Bribery and corruption · Bribery of public officials
Legal basis
Lei 12.846/2013, Art. 5 I und III, Art. 6 I, Arts. 16, 17 und 19 I; Lei 8.429/1992; Decreto 11.129/2022
Action
Fine
Status of proceedings
final
Sector
Energy and utilities
Mitigating circumstances
Credit was given for remediation of damage (1%), cooperation (1.5%) and voluntary admission (2%); no reduction was granted for a compliance programme.
Liability of senior managers
Tolerance or knowledge by management was applied as an aggravating factor at 2.5%.

Original amount 108,710,739.68 BRL, converted at the ECB reference rate of 14 Nov 2024.

Checked against the official source on 3 Oct 2026 · Direct link

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