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.

17cases from 3 jurisdictions
€396.7mTotal of monetary amounts
€14.6mMedian per case with an amount

Click a bar to drill down one level.

When?

per year, by date of decision
Trend
PeriodCasesTotal
20221€15.9m
20235€245m
20241€30,000
20255€68.1m
20265€67.8m

17 cases

19 Mar 2026 Colas Rail Asia Sdn Bhd (Colas-Gruppe)Colas Rail Asia: CJIP of 29.7 million EUR over bribery in metro contracts in Malaysia FranceBribery of public officials €29.7m

The Malaysian subsidiary of Colas Rail paid large, undocumented sums via intermediaries in connection with public contracts for urban rail lines in Kuala Lumpur (Kelana Jaya extension, MRT2). Following an internal investigation, Colas Rail self-reported the matter in 2017; the CJIP (Convention judiciaire d'intérêt public, a French deferred prosecution agreement) provides for a public interest fine of 29,745,974 EUR and a three-year compliance programme monitored by the French Anti-Corruption Agency (AFA) (costs of up to 1.9 million EUR).

What organisations can take from it

Undocumented payments to intermediaries on foreign projects must be stopped early by the finance and compliance functions – self-reporting after an internal investigation is rewarded.

Relevance to training and awareness

Intermediaries and consultants in public tenders

Authority / court
Parquet national financier (PNF); Validierung durch den Präsidenten des Tribunal judiciaire de Paris
Area of law
Bribery and corruption · Bribery of public officials
Legal basis
Art. 41-1-2 Code de procédure pénale (CJIP); Bestechung ausländischer Amtsträger
Action
Fine
Status of proceedings
final
Sector
Construction and real estate
Employees
10,000 or more
Culpability
intentional
Mitigating circumstances
Self-report (criminal complaint filed by Colas Rail on 31 May 2017) following an internal forensic investigation.
Liability of senior managers
The CJIP does not address the criminal liability of natural persons.
Published
19 Mar 2026

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

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19 Mar 2026 Balt USA LLC (Balt-Gruppe)Balt USA: CJIP in France over payments to a hospital physician FranceBribery of public officials €1.77m

In parallel with the US declination, the PNF concluded a CJIP with the US subsidiary of the French medical technology manufacturer for 1,765,493 EUR (after crediting the US disgorgement) and a three-year AFA compliance programme. The case arose from Balt SAS's voluntary self-disclosure of 22 May 2023 concerning conduct at the acquired company Blockade Medical.

What organisations can take from it

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

Relevance to training and awareness

Benefits to hospital physicians, integration of acquired companies

Authority / court
Parquet national financier (PNF); Validierung durch den Präsidenten des Tribunal judiciaire de Paris
Area of law
Bribery and corruption · Bribery of public officials
Legal basis
Art. 41-1-2 Code de procédure pénale (CJIP); aktive und passive Bestechung von Amtsträgern
Action
Fine
Status of proceedings
final
Sector
Healthcare
Employees
250 to 999
Culpability
intentional
Mitigating circumstances
Voluntary self-disclosure to the PNF and the DOJ; coordinated resolution with crediting.
Liability of senior managers
The CJIP does not address the criminal liability of natural persons.
Published
19 Mar 2026

Checked against the official source on 28 Sep 2026 · Version 2 · Direct link

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6 Mar 2026 Fleurette Properties LtdCommodities holding Fleurette: 25.8 million EUR strafbeschikking over bribery in Congo NetherlandsBribery of public officials €25.8m

According to the Dutch Public Prosecution Service (OM), the top holding company of a mining, oil and gold group, which was based in the Netherlands from 2010 to 2017, participated together with others in bribing public officials of the DR Congo in order to obtain licences for cobalt and copper mines. On 6 March 2026, the OM issued a strafbeschikking (prosecutorial penalty order) imposing a fine of 25.8 million EUR, which Fleurette accepted.

What organisations can take from it

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

Relevance to training and awareness

Award of licences in the commodities sector, payments to public officials

Authority / court
Openbaar Ministerie (OM); Ermittlungen FIOD Anti-Corruptie Centrum
Area of law
Bribery and corruption · Bribery of public officials
Legal basis
Buitenlandse ambtelijke omkoping (Wetboek van Strafrecht); OM-strafbeschikking
Action
Fine
Status of proceedings
final
Sector
Steel and metals
Culpability
intentional
Published
10 Mar 2026

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

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18 Feb 2026 Périphériques et Matériels de Contrôle SAS (Groupe Carrus)Betting terminal manufacturer PMC: CJIP over payments to an official in Mali FranceBribery of public officials €499,150

From 2008 to 2011, the Paris-based supplier of betting and gaming terminals made unjustified payments of 78,972 EUR to an official of a majority state-owned company in Mali, with which it had a supply contract awarded without a tender. The case was triggered by a report from TRACFIN (the French financial intelligence unit). Public interest fine of 499,150 EUR (including 335,000 EUR already seized) and a three-year AFA compliance programme.

What organisations can take from it

Managers of state-controlled companies are also public officials – even small private payments to them create a risk of criminal liability for medium-sized companies.

Relevance to training and awareness

Payments to heads of state-owned companies abroad

Authority / court
Parquet national financier (PNF); Validierung durch den Präsidenten des Tribunal judiciaire de Paris
Area of law
Bribery and corruption · Bribery of public officials
Legal basis
Art. 41-1-2 Code de procédure pénale (CJIP); Bestechung ausländischer Amtsträger und Geldwäsche
Action
Fine
Status of proceedings
final
Sector
Telecoms, IT and software
Employees
50 to 249
Culpability
intentional
Liability of senior managers
The CJIP does not address the criminal liability of natural persons.
Published
18 Feb 2026

Checked against the official source on 28 Sep 2026 · Version 2 · Direct link

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10 Feb 2026 Strukton Civiel Projecten B.V. und Strukton International B.V. (Strukton-Gruppe)Construction group Strukton pays 10 million EUR out-of-court settlement over bribery on the Riyadh Metro NetherlandsBribery of public officials €10m

To secure a share in the Riyadh Metro project, around 31 million USD was paid between 2013 and 2021 to an agent representing a high-ranking member of the Saudi royal family; the agent payments were understated to the export credit insurer Atradius. Strukton accepted a transaction (out-of-court settlement) of 10 million EUR.

What organisations can take from it

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

Relevance to training and awareness

Agent commissions and false statements to export credit insurers

Authority / court
Openbaar Ministerie (OM)
Area of law
Bribery and corruption · Bribery of public officials
Legal basis
Buitenlandse ambtelijke omkoping und valsheid in geschrift (Wetboek van Strafrecht); Transactie nach Art. 74 Sr
Action
Fine
Status of proceedings
final
Sector
Construction and real estate
Culpability
intentional
Mitigating circumstances
Cooperation from mid-2023; compliance programme in place since 2017; the employees involved are no longer with the company.
Published
30 Mar 2026

Checked against the official source on 28 Sep 2026 · Version 2 · Direct link

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3 Sep 2025 SURYS SAS (Gruppe Imprimerie Nationale)Hologram manufacturer SURYS: CJIP of 18.4 million EUR in the Ukrainian passport case FranceBribery of public officials €18.4m

From 2013, SURYS supplied security holograms for Ukrainian passports to the state-owned company Polygraph via an interposed Estonian company; the investigation (following a request for mutual legal assistance from Ukraine's National Anti-Corruption Bureau, NABU) concerned misappropriation of public funds, bribery of foreign public officials and money laundering. Public interest fine of 18,363,007 EUR, plus 3,770,000 EUR in damages to the Ukrainian state and a three-year AFA compliance programme.

What organisations can take from it

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

Relevance to training and awareness

Interposed trading companies and sales agents

Authority / court
Parquet national financier (PNF); Validierung durch den Präsidenten des Tribunal judiciaire de Paris
Area of law
Bribery and corruption · Bribery of public officials
Legal basis
Art. 41-1-2 Code de procédure pénale (CJIP); Bestechung ausländischer Amtsträger, Geldwäsche
Action
Fine
Status of proceedings
final
Sector
Other
Employees
250 to 999
Culpability
intentional
Liability of senior managers
The CJIP does not address the criminal liability of natural persons.
Published
3 Sep 2025

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

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27 Jun 2025 IDEMIA France (vormals Oberthur Technologies)Paris prosecutor: CJIP with IDEMIA France for €15.54m over foreign bribery FranceBribery of public officials €15.5m

IDEMIA France, formerly Oberthur Technologies, undertook to pay a public interest fine of 15,541,130 EUR in a CJIP (convention judiciaire d'intérêt public, French deferred prosecution agreement) with the Paris public prosecutor. The investigation opened in 2013, including for bribery of foreign public officials and money laundering, concerned contracts between the Angolan central bank (BNA) and Oberthur Technologies from its former banknote business; validation took place on 27 June 2025.

What organisations can take from it

Contracts with state bodies such as central banks require particularly careful scrutiny of intermediaries and payment flows.

Relevance to training and awareness

Bribery risks in contracts with state central banks

Authority / court
Parquet de Paris (Procureure de la République); Validierung durch das Tribunal judiciaire de Paris
Area of law
Bribery and corruption · Bribery of public officials
Legal basis
Art. 41-1-2 Code de procédure pénale (corruption d'agent public étranger, blanchiment)
Action
Fine
Status of proceedings
final
Sector
Manufacturing and mechanical engineering
Published
27 Jun 2025

Checked against the official source on 2 Oct 2026 · Direct link

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19 Jun 2025 Exclusive Networks Corporate SASIT distributor Exclusive Networks: CJIP of 16 million EUR following a whistleblower report FranceCommercial bribery €16.1m

In 2021, a whistleblower reported payments by subsidiaries in Indonesia, Malaysia, Vietnam, Thailand and India to contractual partners; the investigation concerned private-sector bribery and bribery of foreign public officials. The CJIP provides for a public interest fine of 16,074,511 EUR (including 1 million EUR already seized) and a three-year AFA compliance programme.

What organisations can take from it

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

Relevance to training and awareness

Payments to sales partners in Asia, whistleblowing systems

Authority / court
Parquet national financier (PNF); Validierung durch das Tribunal judiciaire de Paris
Area of law
Bribery and corruption · Commercial bribery
Legal basis
Art. 41-1-2 Code de procédure pénale (CJIP); Bestechung im privaten Sektor und ausländischer Amtsträger
Action
Fine
Status of proceedings
final
Sector
Telecoms, IT and software
Employees
1,000 to 9,999
Culpability
intentional
Liability of senior managers
The CJIP does not address the criminal liability of natural persons.
Published
19 Jun 2025

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

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11 Feb 2025 Paprec GroupPNF: CJIP with Paprec Group for €17.54m after investigation into waste contracts FranceBribery of public officials €17.5m

Paprec Group undertook, in a CJIP (convention judiciaire d'intérêt public, French deferred prosecution agreement), to pay a public interest fine of 17,538,990 EUR, including 4,828,000 EUR already seized, and to implement a three-year compliance programme under the supervision of the Agence française anticorruption (French anti-corruption agency) (costs up to 1,000,000 EUR). The background is a judicial investigation including for bribery, favouritism in procurement, money laundering and unlawful agreements concerning contracts and concessions of French local authorities for waste treatment; validated on 11 February 2025.

What organisations can take from it

Companies that depend on municipal contracts must systematically review contacts with decision-makers and tender processes for bribery and favouritism risks.

Relevance to training and awareness

Integrity in municipal contracts and concessions

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
Action
Fine
Status of proceedings
final
Sector
Energy and utilities
Published
11 Feb 2025

Checked against the official source on 2 Oct 2026 · Direct link

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11 Feb 2025 KLUBB France SASVehicle body builder KLUBB France: CJIP over an ambulance contract in Algeria FranceBribery of public officials €558,024

Following a referral from the public prosecutor's office in Rennes, the PNF investigated bribery of foreign public officials in the performance of a contract for the supply of ambulances to Algeria. KLUBB France is paying a public interest fine of 558,024 EUR and is undergoing a three-year AFA compliance programme.

What organisations can take from it

Medium-sized exporters are also in the spotlight: companies supplying foreign authorities need a robust anti-corruption programme under Sapin II (the French anti-corruption law).

Relevance to training and awareness

Export contracts with state bodies

Authority / court
Parquet national financier (PNF); Validierung durch den Präsidenten des Tribunal judiciaire de Paris
Area of law
Bribery and corruption · Bribery of public officials
Legal basis
Art. 41-1-2 Code de procédure pénale (CJIP); Bestechung ausländischer Amtsträger
Action
Fine
Status of proceedings
final
Sector
Manufacturing and mechanical engineering
Employees
50 to 249
Culpability
intentional
Liability of senior managers
The CJIP does not address the criminal liability of natural persons.
Published
11 Feb 2025

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

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17 Dec 2024 BAM International B.V.OM: penalty order for BAM International over misrecorded facilitation payments NetherlandsBribery of public officials €30,000

The Openbaar Ministerie (OM, Dutch Public Prosecution Service) imposed a penalty order of 30,000 EUR on BAM International B.V. for forgery (valsheid in geschrift): on a completed project in Africa, so-called facilitation payments had been made to officials in connection with a tax dispute, and not all of them were recorded transparently in the accounts. The company had discovered the payments in its own investigation and reported them itself; the amount reflects the OM guideline on self-reporting, cooperation and internal investigation. The OM dropped separate proceedings for bribery of public officials on other projects for lack of evidence.

What organisations can take from it

Even tolerated small payments to officials must be recorded completely and transparently; self-reporting and own investigation reduce the penalty.

Relevance to training and awareness

Facilitation payments and transparent bookkeeping

Authority / court
Openbaar Ministerie (OM), Functioneel Parket
Area of law
Bribery and corruption · Bribery of public officials
Legal basis
Valsheid in geschrift (Urkundenfälschung nach niederländischem Strafrecht); Strafbefehl des OM
Action
Fine
Status of proceedings
unknown
Sector
Construction and real estate
Mitigating circumstances
Self-reporting, own investigation and cooperation with the investigation.
Published
17 Dec 2024

Checked against the official source on 2 Oct 2026 · Direct link

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4 Dec 2023 a French engineering and design firmPNF: CJIP with an engineering firm for €14.6m over suspected foreign bribery FranceBribery of public officialsanonymised €14.6m

The engineering firm undertook to pay a public interest fine of 14,600,000 EUR under a CJIP (convention judiciaire d'intérêt public, French deferred prosecution agreement) concluded on 29 November 2023 and validated on 4 December 2023. The investigation, including for bribery of foreign public officials, stemmed from a criminal complaint through which the company itself had passed audit reports and an anonymous letter to the judicial authorities in 2013.

What organisations can take from it

Internal audit findings and anonymous tip-offs about bribery should be investigated immediately; self-reporting does not, however, rule out a later sanction.

Relevance to training and awareness

Handling internal indications of bribery, and self-reporting

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 (corruption d'agent public étranger)
Action
Fine
Status of proceedings
final
Sector
Construction and real estate
Published
4 Dec 2023

Checked against the official source on 2 Oct 2026 · Company name anonymised since 4 Dec 2025 · Direct link

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4 Dec 2023 a French industrial manufacturer and its groupPNF: CJIP with an industrial manufacturer and its group for €13.37m over foreign bribery FranceBribery of public officialsanonymised €13.4m

The manufacturer undertook, in a CJIP (convention judiciaire d'intérêt public, French deferred prosecution agreement) with the Parquet national financier (PNF, French national financial prosecutor), to pay a public interest fine of 13,373,000 EUR; in addition, the group must implement a three-year compliance programme under the supervision of the Agence française anticorruption (AFA, French anti-corruption agency), the costs of which the manufacturer bears up to 500,000 EUR. It was based on an investigation including for bribery of foreign public officials; validated on 4 December 2023.

What organisations can take from it

Anyone doing business with foreign public officials needs a robust anti-corruption programme – otherwise the authority imposes one, supervision costs included.

Relevance to training and awareness

Sapin II anti-corruption programme under official supervision

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 (corruption d'agent public étranger)
Action
Fine
Status of proceedings
final
Sector
Manufacturing and mechanical engineering
Published
4 Dec 2023

Checked against the official source on 2 Oct 2026 · Company name anonymised since 4 Dec 2025 · Direct link

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28 Jul 2023 a Hungarian pharmaceutical companyPharmaceutical company: 37 million HUF fine over doctors' fees and excess hospitality HungaryGifts, hospitality and benefitsanonymised €96,540

The Országos Gyógyszerészeti és Élelmezés-egészségügyi Intézet (OGYÉI, Hungarian National Institute of Pharmacy and Nutrition) fined a Hungarian pharmaceutical company 37,000,000 HUF and prohibited continuation of the infringements, because the company had in numerous cases granted prescribing doctors unlawful financial benefits through fee contracts – for example for role-plays used to train its own sales representatives, specialist articles for a company-branded promotional publication, promotional lectures, and paid lectures given by heads of department to their own staff. In addition, hospitality exceeded the statutory per-head limit in four cases at its own professional events, support enabling doctors to attend two international professional events was not reported, and there were shortcomings concerning warning symbols in promotional material, the handing out of samples and donation records. The decision was issued in new proceedings after the Fővárosi Törvényszék (Budapest-Capital Regional Court) had annulled an earlier 2020 decision for inadequate reasoning on the amount of the sanction, while upholding the legal assessment of the fee contracts.

What organisations can take from it

Fee contracts with prescribing doctors need a genuine professional service, separate from sales promotion and paid at a fair rate – otherwise they count as a prohibited benefit.

Relevance to training and awareness

Fee contracts, lectures and hospitality for doctors in pharmaceutical marketing

Authority / court
Országos Gyógyszerészeti és Élelmezés-egészségügyi Intézet (OGYÉI; Rechtsnachfolger NNGYK)
Area of law
Bribery and corruption · Gifts, hospitality and benefits
Legal basis
Gyftv. (Gesetz Nr. XCVIII/2006) § 14 Abs. 1, 2 und 10, § 11/B Abs. 2, § 19 Abs. 2 lit. c und d; EüM-Verordnung 3/2009 § 7 Abs. 1 lit. a, § 10 Abs. 3
Action
Fine
Status of proceedings
final
Sector
Chemicals and pharmaceuticals
Published
28 Jul 2023

Original amount 37,000,000 HUF, converted at the ECB reference rate of 28 Jul 2023.

Checked against the official source on 28 Sep 2026 · Company name anonymised since 28 Jul 2025 · Direct link

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28 Jun 2023 a French and a British energy engineering company of the same groupPNF: CJIP with two energy engineering companies for €208.94m FranceBribery of public officialsanonymised €208.9m

Two companies of a former energy engineering group concluded a CJIP (convention judiciaire d'intérêt public, French deferred prosecution agreement) with the Parquet national financier (PNF, French national financial prosecutor) over possible bribery of foreign public officials in connection with contracts concluded in 2008 and 2009 in Ghana and Equatorial Guinea. The French company pays a public interest fine of 54,146,000 EUR and the British company 154,792,000 EUR, 208,938,000 EUR in total; the agreement was validated on 28 June 2023.

What organisations can take from it

In large contracts with state energy companies, intermediaries' contacts with public officials and their relatives must be scrutinised with particular care.

Relevance to training and awareness

Bribery of foreign public officials in major energy projects

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 (corruption d'agent public étranger)
Action
Fine
Status of proceedings
final
Sector
Energy and utilities
Published
28 Jun 2023

Checked against the official source on 2 Oct 2026 · Company name anonymised since 28 Jun 2025 · Direct link

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17 May 2023 a French construction company and a property developer of the same construction groupPNF: CJIP with a construction company and a property developer for €7.96m FranceBribery of public officialsanonymised €7.96m

The two companies of a French construction group undertook, in a CJIP (convention judiciaire d'intérêt public, French deferred prosecution agreement), to pay a public interest fine totalling 7,964,000 EUR and to implement a three-year compliance programme under the supervision of the Agence française anticorruption (French anti-corruption agency), the costs of which the construction company bears up to 1,337,000 EUR. The investigation opened in 2021 concerned, among other things, favouritism in public procurement (favoritisme) and active and passive bribery of public officials; validated on 17 May 2023.

What organisations can take from it

Contacts with public contracting authorities during tender procedures must be clearly regulated and documented to avoid allegations of favouritism.

Relevance to training and awareness

Bribery and favouritism in public construction contracts

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 (favoritisme, corruption d'agent public)
Action
Fine
Status of proceedings
final
Sector
Construction and real estate
Published
17 May 2023

Checked against the official source on 2 Oct 2026 · Company name anonymised since 17 May 2025 · Direct link

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30 Nov 2022 a European aerospace groupPNF: second CJIP with an aerospace group for €15.86m over suspected bribery FranceBribery of public officialsanonymised €15.9m

In a second convention judiciaire d'intérêt public (CJIP, French deferred prosecution agreement), following the one of 2020, the group undertook to pay a public interest fine of 15,856,044 EUR to the Parquet national financier (PNF, French national financial prosecutor). It concerns payments to sales intermediaries in sales campaigns in Libya and Kazakhstan and through a further intermediary, which the prosecutor mostly regards as possible bribery of foreign public officials and, in one helicopter deal in Kazakhstan, as possible bribery of a French elected official; the amount corresponds to the fees paid to the intermediaries in Libya and Kazakhstan. The agreement, concluded on 17 November 2022, was validated by the court on 30 November 2022.

What organisations can take from it

Commissions paid to sales intermediaries need a documented service in return and documented checks, otherwise sanctions may follow even years later.

Relevance to training and awareness

Risks of commissions paid to sales intermediaries in international business

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; Art. 435-3, 433-1 Code pénal
Action
Fine
Status of proceedings
final
Sector
Manufacturing and mechanical engineering
Employees
10,000 or more
Published
30 Nov 2022

Checked against the official source on 2 Oct 2026 · Company name anonymised since 30 Nov 2024 · Direct link

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