Compliance Radar
Who was sanctioned, and for what?
Fines, court rulings and incidents from Europe and North America: 756 cases from 32 jurisdictions, each with an official source and checked against that source before publication. Filter by country, area of law and sector. Click a chart to drill down one level.
Click a bar to drill down one level.
Where?
by levelWhat for?
by topicWho?
by sectorAll sectors
- Chemicals and pharmaceuticals €4.97bn 88 % · 6 cases
- Defence and security €338.4m 6 % · 1 case
- Healthcare €127.8m 2 % · 10 cases
- Telecoms, IT and software €102.1m 2 % · 1 case
- Transport, logistics and shipping €53.5m 1 % · 1 case
- Media and online platforms €24.8m 0 % · 1 case
- Manufacturing and mechanical engineering €10.5m 0 % · 2 cases
- Food and agriculture €8.91m 0 % · 1 case
- Financial services and insurance €4.04m 0 % · 1 case
When?
per quarter, by date of decision| Period | Cases | Total |
|---|---|---|
| Q3 2023 | 1 | €24.8m |
| Q4 2023 | 0 | — |
| Q1 2024 | 0 | — |
| Q2 2024 | 1 | €11.1m |
| Q3 2024 | 3 | €44.7m |
| Q4 2024 | 3 | €393.5m |
| Q1 2025 | 0 | — |
| Q2 2025 | 1 | €177.8m |
| Q3 2025 | 1 | €4.04m |
| Q4 2025 | 2 | €107.9m |
| Q1 2026 | 2 | €1.9m |
| Q2 2026 | 4 | €4.79bn |
| Q3 2026 | 6 | €80.8m |
24 cases
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 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, 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.
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
- Former CEO pays under a separate settlement.
Original amount 36,400,000 USD, converted at the ECB reference rate of 30 Jul 2026.
- HHS-OIG Enforcement Actions: Texas Laboratory, Former CEO, and Florida Businessman Pay a Total of $36.4M … (30.07.2026) Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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20 Jul 2026 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
- The customs broker Carlos Leopoldo Alvelais has pleaded guilty.
- Published
- 17 Jul 2026
Original amount 10,183,872 USD, converted at the ECB reference rate of 17 Jul 2026.
- Agricultural Company to Pay Over $10M to Resolve Foreign Bribery Case Press release of an authority
- Deferred Prosecution Agreement, United States v. The Scoular Company, 3:26-cr-01685-KC (W.D. Tex.), filed 07/17/26 Decision of an authority
- DOJ Criminal Division: United States v. The Scoular Company (Fallseite) Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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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, 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.
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
- 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.
- HHS-OIG Enforcement Actions: Arkansas Pathology Laboratory and Its Owners Pay $30M … (17.06.2026) Enforcement database of an authority
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 €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 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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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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17 Mar 2026 Balt SAS / Balt USA LLCMedical technology: DOJ declination for Balt SAS after bribery of a hospital physician €1.05m
Through sham consultancy agreements, fictitious invoices and purported bonus payments, around 602,000 USD in bribes flowed from 2017 to 2023 via a Belgian consultant to a physician in a senior position at a French public hospital, so that the hospital would purchase embolisation coils from Balt. The DOJ declined to prosecute on account of voluntary self-disclosure, cooperation and remediation (declination of 17 March 2026); Balt is disgorging 1,214,797 USD in profits.
Physicians at public hospitals are public officials – consultancy agreements with them require documented services and approval by the compliance function.
Benefits to physicians in the public healthcare sector, sham consultancy agreements
- Authority / court
- U.S. Department of Justice (Criminal Division, Fraud Section)
- Area of law
- Bribery and corruption · Bribery of public officials
- Legal basis
- FCPA; Corporate Enforcement and Voluntary Self-Disclosure Policy (Declination)
- Action
- Disgorgement of profits
- Status of proceedings
- final
- Sector
- Healthcare
- Culpability
- intentional
- Mitigating circumstances
- Voluntary self-disclosure (including to the French national financial prosecutor's office, PNF), full cooperation, timely remediation, disciplinary measures, parallel resolution in France.
- Liability of senior managers
- A former manager of the US subsidiary (David Ferrera) and a consultant (Marc Tilman) were charged with FCPA violations and money laundering.
- Published
- 19 Mar 2026
Original amount 1,214,797 USD, converted at the ECB reference rate of 17 Mar 2026.
- Justice Department Resolves Foreign Bribery Investigation with Balt SAS; Healthcare Executive and Sales Consultant Indicted Press release of an authority
- Communiqué de presse du procureur de la République financier – CJIP BALT USA (19.03.2026) Press release of an authority
- DOJ Criminal Division, Fraud Section: Declination Letter Re: Balt SAS (17.03.2026) Decision of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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5 Mar 2026 Allin IP DX LLCAllin IP DX: 980,000 USD after self-disclosure over paid referral marketers €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.
Early self-disclosure limits the damage – but this requires the compliance function to actually get to see problematic sales contracts.
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.
- HHS-OIG Enforcement Actions: Sarasota Lab Agrees to Pay $980,000 to Resolve False Claims Act Violations (05.03.2026) Enforcement database of an authority
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 €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.
Cooperation agreements between hospitals and office-based practices must properly document services and remuneration – otherwise payments are treated as referral bonuses.
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.
- HHS-OIG Enforcement Actions: U.S. Attorney Announces $6.8 Million Settlement With New York-Presbyterian Hudson Valley Hospital … (22.12.2025) Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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12 Nov 2025 Comunicaciones Celulares S.A. (TIGO Guatemala)TIGO Guatemala pays more than 118 million USD for bribing members of Congress €102.1m
From 2012 to 2018, the Guatemalan mobile network operator made monthly cash payments to members of Congress or their security staff in order to obtain legislative support; part of the funds came from laundered drug money. Two-year Deferred Prosecution Agreement with a criminal penalty of 60 million USD and administrative forfeiture of 58,198,343 USD.
In joint ventures with local partners, the parent company needs genuine control over cash flows and contacts with public officials – an early voluntary self-disclosure is no substitute for a full investigation.
Bribery of public officials, cash payments, integrity of co-shareholders
- Authority / court
- U.S. Department of Justice (Criminal Division, Fraud Section; USAO Southern District of Florida)
- Area of law
- Bribery and corruption · Bribery of public officials
- Legal basis
- FCPA, 15 U.S.C. § 78dd-3 (Verschwörung, 18 U.S.C. § 371); Deferred Prosecution Agreement
- Action
- Fine
- Status of proceedings
- final
- Sector
- Telecoms, IT and software
- Culpability
- intentional
- Mitigating circumstances
- Voluntary self-disclosure by the parent company Millicom in 2015; subsequently extensive cooperation and remediation (including dismissals of staff and an 800 % increase in compliance personnel).
- Liability of senior managers
- According to the DOJ, the scheme was directed by the then Guatemalan shareholder and other senior individuals; four individuals had already been charged (not named).
- Published
- 12 Dec 2025
Original amount 118,198,343 USD, converted at the ECB reference rate of 12 Nov 2025.
- TIGO Guatemala Paid Over $118M to Resolve Foreign Bribery Investigation Press release of an authority
- Deferred Prosecution Agreement, United States v. Comunicaciones Celulares S.A. d/b/a TIGO Guatemala (Case 1:25-cr-20476) Decision of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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7 Aug 2025 Liberty Mutual Insurance CompanyLiberty Mutual: declination against 4.7 million USD after bribery of Indian state bank employees €4.04m
From 2017 to 2022, the Indian subsidiary Liberty General Insurance paid around 1.47 million USD to employees of six state-owned banks so that they would refer bank customers to its insurance products; the payments were booked as marketing expenses and routed through third parties. The DOJ declined to prosecute; Liberty Mutual is disgorging 4,699,088 USD in profits.
Employees of state-owned banks are public officials – sales commissions paid to them are bribes, even if they are booked as marketing.
Distribution partnerships with state-owned banks, payments disguised as marketing
- Authority / court
- U.S. Department of Justice (Fraud Section; USAO District of Massachusetts)
- Area of law
- Bribery and corruption · Bribery of public officials
- Legal basis
- FCPA, 15 U.S.C. § 78dd-2; Corporate Enforcement and Voluntary Self-Disclosure Policy (Declination)
- Action
- Disgorgement of profits
- Status of proceedings
- final
- Sector
- Financial services and insurance
- Employees
- 10,000 or more
- Culpability
- intentional
- Mitigating circumstances
- Voluntary self-disclosure (March 2024), full cooperation, root cause analysis, termination of those involved, improved controls including rules on messaging apps.
- Published
- 7 Aug 2025
Original amount 4,699,088 USD, converted at the ECB reference rate of 7 Aug 2025.
- DOJ Declination Letter – Liberty Mutual Insurance Company (07.08.2025) Decision of an authority
- DOJ Criminal Division: CEP Declinations Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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28 Apr 2025 Gilead Sciences, Inc.Gilead: 202 million USD – speaker programmes with fees, luxury meals and travel €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.
Selecting speakers by prescription volume turns continuing education into bribery – selection criteria and hospitality limits must be documented.
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.
- HHS-OIG Enforcement Actions: U.S. Attorney Announces $202 Million Settlement With Gilead Sciences … Speaker Programs (29.04.2025) Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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19 Dec 2024 AAR Corp.Aviation services provider AAR pays 55.6 million USD for bribery in Nepal and South Africa €53.5m
Through an agent and a joint venture partner, AAR paid sham commissions to public officials in order to secure the sale of two Airbus A330s to Nepal Airlines and maintenance services for South African Airways Technical. SEC: 23,451,100 USD in disgorgement and 5,785,524 USD in interest; DOJ criminal penalty of 26,363,029 USD under a Non-Prosecution Agreement.
State-owned airlines are public contracting entities – scrutinise commissions to intermediaries in aircraft transactions rigorously.
Agents and joint venture partners in transactions with state-owned airlines
- Authority / court
- U.S. Securities and Exchange Commission (SEC); U.S. Department of Justice
- Area of law
- Bribery and corruption · Bribery of public officials
- Legal basis
- FCPA (Anti-Bestechung, Buchführung, interne Kontrollen); Non-Prosecution Agreement
- Action
- Fine
- Status of proceedings
- final
- Sector
- Transport, logistics and shipping
- Employees
- 1,000 to 9,999
- Culpability
- intentional
- Mitigating circumstances
- Disclosure following press reports, cooperation (forensics, translations, witnesses) and remedial measures.
- Liability of senior managers
- A former senior employee of an AAR subsidiary, Deepak Sharma (named in the SEC order), was involved.
- Published
- 19 Dec 2024
Original amount 55,599,653 USD, converted at the ECB reference rate of 19 Dec 2024.
- SEC Order In the Matter of AAR Corp., Release No. 101987 (19.12.2024) Decision of an authority
- DOJ Criminal Division: Non-Prosecution Agreement Re: AAR Corp. (19.12.2024) Decision of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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16 Oct 2024 RTX Corporation (Raytheon Company)RTX (Raytheon) pays around 391 million USD for bribing a Qatari military official €338.4m
From 2011 to 2017, Raytheon paid almost 2 million USD via sham subcontracts to Qatari military and other public officials and more than 30 million USD to an agent from the ruling family. SEC order: disgorgement of 37,400,090 USD, interest of 11,786,208 USD and a penalty of 75 million USD (of which 22.5 million USD was credited against the DOJ payment); under the DPA with the DOJ, 267,096,068 USD (230.4 million penalty, 36,696,068 forfeiture) is attributable to the FCPA part, combined with an Arms Export Control Act violation and a three-year monitorship. Total without double counting: 368,782,366 USD.
Subcontracts without verifiable services are a classic vehicle for bribes – defence exporters must also disclose payment flows to export control authorities.
Sham subcontracts and agents in defence transactions
- Authority / court
- U.S. Securities and Exchange Commission (SEC); U.S. Department of Justice
- Area of law
- Bribery and corruption · Bribery of public officials
- Legal basis
- FCPA (Anti-Bestechung, Buchführung, interne Kontrollen, Sections 30A, 13(b)(2)(A)/(B) Exchange Act); Arms Export Control Act; DPA
- Action
- Fine
- Status of proceedings
- final
- Sector
- Defence and security
- Employees
- 10,000 or more
- Culpability
- intentional
- Published
- 16 Oct 2024
Original amount 368,782,366 USD, converted at the ECB reference rate of 16 Oct 2024.
- SEC Order In the Matter of RTX Corporation, Release No. 101353 (16.10.2024) Decision of an authority
- SEC Enforcement Actions: FCPA Cases Enforcement database of an authority
- DOJ Criminal Division: U.S. v. Raytheon Company, Docket No. 24-CR-399 (RER) Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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11 Oct 2024 Moog Inc.Moog: SEC order over bribery of Indian public officials by a subsidiary €1.54m
From 2020 to 2022, employees of the Indian subsidiary of the aerospace and defence supplier bribed Indian public officials via agents and distributors, among other things to tailor tenders in Moog's favour; the payments were booked as business expenses. Payment of 504,926 USD in disgorgement, 78,889 USD in interest and a penalty of 1.1 million USD.
Even small foreign subsidiaries need effective controls over payments to distributors and agents – otherwise the listed parent company is liable under the books-and-records provisions.
Influencing tender conditions via distributors
- Authority / court
- U.S. Securities and Exchange Commission (SEC)
- Area of law
- Bribery and corruption · Bribery of public officials
- Legal basis
- FCPA Buchführungs- und interne Kontrollvorschriften (Sections 13(b)(2)(A)/(B) Exchange Act)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Manufacturing and mechanical engineering
- Culpability
- intentional
- Mitigating circumstances
- Cooperation (sharing of internal investigation findings) and remediation, including termination of employees and third parties.
- Published
- 11 Oct 2024
Original amount 1,683,815 USD, converted at the ECB reference rate of 11 Oct 2024.
- SEC Order In the Matter of Moog Inc., Release No. 101307 (11.10.2024) Decision of an authority
- SEC Enforcement Actions: FCPA Cases Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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10 Sep 2024 Deere & CompanyDeere pays 9.9 million USD: Wirtgen Thailand bribed the air force and the highways authority €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.
After acquisitions, integrate subsidiaries swiftly into the compliance programme and controls – otherwise old practices such as luxury trips for customers live on.
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.
- SEC Order In the Matter of Deere & Company, Release No. 100984 (10.09.2024) Decision of an authority
- SEC Enforcement Actions: FCPA Cases Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link