Compliance Radar
Who was sanctioned, and for what?
Fines, court rulings and incidents from Europe and North America: 718 cases from 32 jurisdictions, each with an official source and checked against that source before publication. Filter by country, area of law and sector. Click a chart to drill down one level.
Click a bar to drill down one level.
Where?
by levelWhat for?
by action- Fine €529.2m 99 % · 6 cases
- Disgorgement of profits €5.09m 1 % · 2 cases
Who?
by sectorAll sectors
- Defence and security €338.4m 63 % · 1 case
- Telecoms, IT and software €102.1m 19 % · 1 case
- Transport, logistics and shipping €53.5m 10 % · 1 case
- Media and online platforms €24.8m 5 % · 1 case
- Food and agriculture €8.91m 2 % · 1 case
- Financial services and insurance €4.04m 1 % · 1 case
- Manufacturing and mechanical engineering €1.54m 0 % · 1 case
- Healthcare €1.05m 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 | 0 | — |
| Q3 2024 | 0 | — |
| Q4 2024 | 3 | €393.5m |
| Q1 2025 | 0 | — |
| Q2 2025 | 0 | — |
| Q3 2025 | 1 | €4.04m |
| Q4 2025 | 1 | €102.1m |
| Q1 2026 | 1 | €1.05m |
| Q2 2026 | 0 | — |
| Q3 2026 | 1 | €8.91m |
8 cases
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 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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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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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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28 Sep 2023 Clear Channel Outdoor Holdings Inc.Clear Channel Outdoor: 26.1 million USD – gifts and hospitality for Chinese officials €24.8m
From at least 2012 to 2017, the Chinese majority-owned subsidiary Clear Media bribed officials with expensive gifts and hospitality and used sham intermediaries and false invoices to fund concealed consultants in order to obtain advertising space, for example at bus stops; the payments were booked as entertainment, cleaning and customer development expenses. Despite repeated warnings from internal audit, adequate controls were lacking until 2019; Clear Channel paid 16,355,567 USD in disgorgement, 3,760,920 USD in interest and a civil penalty of 6 million USD (a total of 26,116,487 USD).
Internal audit findings on entertainment and consultancy costs in high-risk markets must lead to immediate controls.
Gifts and hospitality for public officials; correct booking
- Authority / court
- U.S. Securities and Exchange Commission (SEC)
- Area of law
- Bribery and corruption · Bribery of public officials
- Legal basis
- Foreign Corrupt Practices Act (Anti-Bribery, Books and Records, Internal Accounting Controls)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Media and online platforms
Original amount 26,116,487 USD, converted at the ECB reference rate of 28 Sep 2023.
Checked against the official source on 25 Sep 2026 · Direct link