Who was sanctioned, and for what?

A head of unit at the Higher Regional Court of Jena (OLG Jena) responsible for budget, procurement and personnel of the Thuringian judiciary obtained fourteen loans (375 to 10,000 EUR) from two co-defendants between 2013 and 2019, coupled with the tacit expectation that he would take them into account when awarding contracts; he also concluded service contracts in breach of public procurement law (damage exceeding 450,000 EUR). The Regional Court of Gera (LG Gera) imposed an aggregate suspended prison sentence of two years and confiscation. Germany's Federal Court of Justice (Bundesgerichtshof, BGH) upheld the conviction for accepting benefits (Vorteilsannahme, not Bestechlichkeit, i.e. taking bribes) in 13 cases, discontinued one time-barred case and set aside the aggregate sentence and the amount of the daily fine rate; the defendant's appeal on points of law will be decided separately.

Authority / court

Bundesgerichtshof (2. Strafsenat); Vorinstanz Landgericht Gera

Area of law

Bribery and corruption · Bribery of public officials

Legal basis

§ 331 StGB (Vorteilsannahme), § 266 StGB (Untreue); BGH 2 StR 554/25

Action

Custodial sentence

Status of proceedings

under appeal

Sector

Public sector

Culpability

intentional

Liability of senior managers

The former head of unit (a management function in the judicial administration) was convicted; two lenders were co-defendants.

Published

23 Sep 2026

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

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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.

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.

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

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The British defence supplier failed to prevent bribery by agents in connection with three public contracts in Oman and Algeria (including a contract with the Omani Ministry of Transport worth up to 200 million GBP). The DPA approved by Southwark Crown Court provides for a penalty of 10,083,150 GBP; in addition, the company is bearing around 4.8 million GBP of the SFO's investigation costs and must report on its compliance programme for three years.

Authority / court

Serious Fraud Office (SFO)

Area of law

Bribery and corruption · Bribery of public officials

Legal basis

Section 7 Bribery Act 2010 (Failure to prevent bribery); Deferred Prosecution Agreement

Action

Fine

Status of proceedings

final

Sector

Defence and security

Culpability

intentional

Mitigating circumstances

Self-report of the Algerian matters in 2018; restructuring of ownership and leadership; 45 % discount on the penalty.

Published

1 May 2026

Original amount 10,083,150 GBP, converted at the ECB reference rate of 30 Apr 2026.

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

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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).

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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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 offences committed by a former manager of the acquired company Blockade Medical.

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 25 Sep 2026 · Direct link

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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.

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.

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

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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.

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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From 2008 to 2011, the Paris-based supplier of betting and gaming terminals made unjustified payments of 78,972 EUR to the head of the majority state-owned Pari Mutuel Urbain 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.

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 25 Sep 2026 · Direct link

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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.

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.

Liability of senior managers

The Dutch Public Prosecution Service (OM) is considering prosecuting several natural persons involved (not named).

Published

30 Mar 2026

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

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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.

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.

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

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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.

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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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.

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.

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

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From 2015 to 2019, the managing director of a supplier of landfill technology granted the managing director of a waste management company controlled by two German federal states benefits of around 696,325 EUR and in return received preferential contracts. Because the waste management company is state-controlled, its head was deemed a public official. The prison sentence of 3 years and 6 months is final; the confiscation of 1,982,658.63 EUR must be decided afresh.

Authority / court

Bundesgerichtshof (6. Strafsenat); Vorinstanz Landgericht Neuruppin

Area of law

Bribery and corruption · Bribery of public officials

Legal basis

§ 334 StGB (Bestechung) i. V. m. § 11 Abs. 1 Nr. 2 c StGB; BGH 6 StR 315/24; LG Neuruppin 13 KLs 26/23

Action

Custodial sentence

Status of proceedings

final

Sector

Energy and utilities

Culpability

intentional

Liability of senior managers

The supplier's managing director was sentenced to 3 years and 6 months' imprisonment.

Published

5 Jan 2026

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

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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.

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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Between 2009 and 2011, more than 4 million EUR and more than 600,000 USD were paid to a senior employee of the Angolan state oil distributor in order to promote ship chartering and bunkering business of the Trafigura group. The court convicted the then parent company for lacking rules on the supervision of intermediaries, imposing a fine of 3 million CHF and a compensatory claim (Ersatzforderung) of 145,634,268 USD (amount converted at the ECB rate of 31 January 2025: 148,933,982 USD in total); three individuals received prison sentences. It was the first judgment of the Federal Criminal Court on corporate criminal liability for foreign bribery; it is not final.

Authority / court

Bundesstrafgericht (Strafkammer); Anklage durch die Bundesanwaltschaft

Area of law

Bribery and corruption · Bribery of public officials

Legal basis

Art. 102 StGB i. V. m. Art. 322septies StGB (Bestechung fremder Amtsträger); SK.2023.49

Action

Fine

Status of proceedings

unknown

Sector

Energy and utilities

Employees

10,000 or more

Culpability

intentional

Liability of senior managers

A former senior manager of the group received a prison sentence of 32 months (12 of them unsuspended), the intermediary 24 months suspended, and the Angolan public official 36 months (names anonymised).

Published

31 Jan 2025

Original amount 148,933,982 USD, converted at the ECB reference rate of 31 Jan 2025.

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

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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.

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.

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

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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.

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.

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

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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.

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.

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

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Glencore failed to take all reasonable organisational precautions to prevent the bribery of foreign public officials by a business partner in connection with the acquisition of minority stakes in two mining companies in the DR Congo in 2011. The Office of the Attorney General of Switzerland (Bundesanwaltschaft, BA) issued a summary penalty order (Strafbefehl) imposing a fine of 2 million CHF and a compensatory claim of 150 million USD (amount converted at the ECB rate of 5 August 2024: 152,357,266 USD in total); further matters from 2007–2017 were discontinued.

Authority / court

Bundesanwaltschaft (BA)

Area of law

Bribery and corruption · Bribery of public officials

Legal basis

Art. 102 Abs. 2 StGB (Unternehmensverantwortlichkeit) i. V. m. Bestechung fremder Amtsträger; Strafbefehl

Action

Fine

Status of proceedings

unknown

Sector

Steel and metals

Employees

10,000 or more

Culpability

intentional

Published

5 Aug 2024

Original amount 152,357,266 USD, converted at the ECB reference rate of 5 Aug 2024.

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

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A British Ministry of Defence official seconded to a defence contractor accepted more than 70,000 GBP (44,000 GBP in cash and two cars) in return for commissioning work from offshore consultants. He was convicted of misconduct in public office and sentenced to 30 months' imprisonment, with a confiscation order of 123,000 GBP; the associated company GPT had already pleaded guilty in 2021.

Authority / court

Serious Fraud Office (SFO)

Area of law

Bribery and corruption · Bribery of public officials

Legal basis

Misconduct in public office (Common Law); Proceeds of Crime Act (Confiscation)

Action

Custodial sentence

Status of proceedings

unknown

Sector

Defence and security

Culpability

intentional

Liability of senior managers

The former MoD official Jeffrey Cook was personally sentenced to imprisonment.

Published

12 Apr 2024

Original amount 123,000 GBP, converted at the ECB reference rate of 12 Apr 2024.

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

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The Geneva-based commodities trading house failed to take all reasonable organisational precautions to prevent foreign public officials from being bribed on its behalf in connection with the Ecuadorian oil industry from 2013 to 2017. The Office of the Attorney General of Switzerland (BA) – in coordination with US authorities – ordered Gunvor to pay around 86.7 million CHF, of which 4.3 million CHF is a fine.

Authority / court

Bundesanwaltschaft (BA)

Area of law

Bribery and corruption · Bribery of public officials

Legal basis

Art. 102 StGB (Unternehmensverantwortlichkeit) i. V. m. Bestechung fremder Amtsträger

Action

Fine

Status of proceedings

unknown

Sector

Energy and utilities

Culpability

intentional

Published

1 Mar 2024

Original amount 86,700,000 CHF, converted at the ECB reference rate of 1 Mar 2024.

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

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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).

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

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