Who was sanctioned, and for what?

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.

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.

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

The nationwide wine and spirits distributor headquartered in Florida entered into a non-prosecution agreement and pays USD 12.5 million. It admitted that executives and employees had for years provided employees of alcohol retailers, including grocery chains in California, with cash, prepaid gift cards, flights, golf trips, resort stays and luxury goods to influence the purchase and placement of its products, concealing this through third-party vendors and false invoices. The authority allegedly made the findings set out here; this account is not based on a final judgment.

Authority / court

U.S. Attorney's Office, Northern District of California (U.S. Department of Justice)

Area of law

Bribery and corruption · Commercial bribery

Action

Other

Status of proceedings

final

Sector

Retail and e-commerce

Liability of senior managers

According to the announcement, several California-based executives, including vice presidents, were directly involved.

Published

10 Sep 2026

Original amount 12,500,000 USD, converted at the ECB reference rate of 10 Sep 2026.

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

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.

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

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

The Houston laboratory allegedly paid kickbacks and billed Medicare and Medicaid for medically unnecessary genetic tests. The settlements with the laboratory and other parties add up to 36.4 million USD (combined total); the laboratory is subject to a Corporate Integrity Agreement.

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

Measures against individuals are not reported here.

Original amount 36,400,000 USD, converted at the ECB reference rate of 30 Jul 2026.

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

Arla Foods Ingredientes Comércio de Produtos Alimentícios Unipessoal Ltda. entered into a leniency agreement with the Controladoria-Geral da União (CGU, Office of the Comptroller General) and the Advocacia-Geral da União (AGU, Office of the Attorney General) concerning violations of the Anti-Corruption Law described in an unpublished annex; it had been the first to come forward, in October 2022. The alleged fine of BRL 31,056.36 derives from a preliminary fine of BRL 93,150.45, based on 2021 gross revenue of BRL 6,210,029.68, reduced by 66.66% for self-reporting, degree of cooperation and payment terms.

Authority / court

Controladoria-Geral da União (CGU) und Advocacia-Geral da União (AGU)

Area of law

Bribery and corruption

Legal basis

Lei nº 12.846/2013, Art. 16 und 17; Decreto nº 11.129/2022, Art. 22, 23 und 47; Lei nº 8.429/1992

Action

Fine

Status of proceedings

final

Sector

Food and agriculture

Mitigating circumstances

Total reduction of 66.66% (22.22% each for self-reporting, degree of cooperation and payment terms); compensation for losses, cooperation and voluntary admission also counted as mitigating factors in the calculation.

Liability of senior managers

As an aggravating factor, the CGU found that management tolerated or was aware of the acts (3% uplift).

Original amount 31,056.36 BRL, converted at the ECB reference rate of 23 Jul 2026.

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

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.

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.

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

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.

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.

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

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

Measures against individuals are not reported here.

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 28 Sep 2026 · Version 3 · Direct link

The Controladoria-Geral da União (CGU, Office of the Comptroller General) imposed on RSX Informática Ltda. a fine of BRL 8,794,574.67, extraordinary publication of the decision and a three-year ban on tendering for and contracting with the Federal Union, including removal from the supplier register SICAF. The case concerned fraud in a tender (pregão nº 5/2017) of the former Ministry of National Integration and in the resulting contracts; through the price registration agreement, other federal bodies, including the social security institute INSS with a software contract, contracted with the company without holding their own tender.

Authority / court

Controladoria-Geral da União (CGU)

Area of law

Bribery and corruption

Legal basis

Lei nº 12.846/2013, Art. 5 IV d, Art. 6 I und II; Lei nº 10.520/2002, Art. 7

Action

Fine

Status of proceedings

unknown

Sector

Telecoms, IT and software

Published

10 Jul 2026

Original amount 8,794,574.67 BRL, converted at the ECB reference rate of 9 Jul 2026.

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

IRB-Brasil Resseguros S.A. concluded a Termo de Compromisso (settlement in sanction proceedings) with the CGU and allegedly pays a fine of BRL 6,317,473.41 because the company had hindered the investigative and supervisory activity of the insurance supervisor SUSEP (Art. 5 V Lei 12.846/2013). The fine equals the statutory minimum of 0.1% of gross revenue (BRL 6,509,921.81) less BRL 192,448.40 already paid in SUSEP proceedings over inconsistent reporting. Extraordinary publication was waived, and the proceedings are thereby closed.

Authority / court

Controladoria-Geral da União (CGU)

Area of law

Bribery and corruption

Legal basis

Lei 12.846/2013, Art. 5 V, Art. 6 I; Decreto 11.129/2022, Art. 25 § 2; Portaria Normativa CGU 155/2024

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Repeat case

no

Mitigating circumstances

Credit was given for a compliance programme (3.6%), the absence of proof of advantage or damage (1%) and settlement-related reductions for cooperation and admission; fines already paid to SUSEP were deducted.

Published

3 Jul 2026

Original amount 6,317,473.41 BRL, converted at the ECB reference rate of 2 Jul 2026.

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

The Arkansas pathology laboratory and its management company allegedly granted unlawful kickbacks and ordered medically unnecessary tests. The settlement of 30 million USD is a joint payment by all settling parties; the laboratory entered into a Corporate Integrity Agreement.

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

Measures against individuals are not reported here.

Original amount 30,000,000 USD, converted at the ECB reference rate of 17 Jun 2026.

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

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.

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.

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

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

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.

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.

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

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.

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.

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

The CGU imposed on the Colônia dos Pescadores Z-12 do Médio Rio Doce a fine of BRL 7,180,921.47 and extraordinary publication of the decision. Acting together with others, the association had falsified its members' applications for entry in the fishing register (RGP) and backdated records and had interfered with the federal fisheries office in Espírito Santo, so that false data found their way into official documents and compensation from the Fundação Renova, together with lawyers' fees, was paid out without entitlement (Art. 5 II, III and V Lei 12.846/2013).

Authority / court

Controladoria-Geral da União (CGU)

Area of law

Bribery and corruption

Legal basis

Lei 12.846/2013, Art. 5 II, III und V, Art. 6 I und II, Art. 14; Decreto 11.129/2022, Arts. 19, 22 und 23

Action

Fine

Status of proceedings

unknown

Sector

Food and agriculture

Liability of senior managers

Measures against individuals are not set out here.

Published

5 May 2026

Original amount 7,180,921.47 BRL, converted at the ECB reference rate of 24 Apr 2026.

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

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

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.

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

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

Measures against individuals are not reported here.

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 28 Sep 2026 · Version 3 · Direct link

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

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.

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.

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

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.

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

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.

Published

30 Mar 2026

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

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

Authority / court

Controladoria-Geral da União (CGU) und Advocacia-Geral da União (AGU)

Area of law

Bribery and corruption · Bribery of public officials

Legal basis

Lei 12.846/2013, Art. 5 I, Art. 6 I, Arts. 16 und 17; Decreto 11.129/2022

Action

Fine

Status of proceedings

final

Sector

Food and agriculture

Mitigating circumstances

For JBJ, credit was given for restitution or compensation (1%), cooperation (1.5%), voluntary admission (2%) and an applied compliance programme (2.5%); overall a 66.6% reduction on the full fine of BRL 93,283,735.64.

Liability of senior managers

For JBJ, tolerance or knowledge by management (3%) and the concurrence of several offences (3%) were aggravating factors.

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

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

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

Authority / court

Controladoria-Geral da União (CGU)

Area of law

Bribery and corruption

Legal basis

Lei nº 12.846/2013, Art. 5 IV a, Art. 6 I und II; Lei nº 10.520/2002, Art. 7

Action

Fine

Status of proceedings

final

Sector

Telecoms, IT and software

Published

12 Jan 2026

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

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

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.

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.

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

On an application by the Australian Securities and Investments Commission (ASIC), the Federal Court of Australia allegedly imposed civil penalties totalling 925,000 AUD: 575,000 AUD on the licensee R M Capital and 350,000 AUD on its authorised representative The SMSF Club. Between November 2014 and July 2016 SMSF Club accepted referral fees totalling 135,863.65 AUD (excluding GST) on 52 occasions from a property provider that referred clients to it, who then set up self-managed superannuation funds (SMSFs) with its help and used them to buy property from that provider; the court treated this as prohibited conflicted remuneration, and R M Capital, as licensee, had through gross negligence failed to take reasonable steps to prevent it. Both companies must provide ASIC with an independent expert's report on their compliance arrangements within six months; R M Capital lodged an appeal on 15 January 2026. The decision is not final.

Authority / court

Federal Court of Australia (Verfahren der Australian Securities and Investments Commission, ASIC)

Area of law

Bribery and corruption · Gifts, hospitality and benefits

Legal basis

Corporations Act 2001 (Cth) s 963F, s 963G(1), s 1317G(1E), s 1101B(1)(a)(i)

Action

Fine

Status of proceedings

under appeal

Sector

Financial services and insurance

Culpability

negligent

Repeat case

no

Mitigating circumstances

For SMSF Club, ASIC and the company submitted as mitigating that it ended the referral arrangement immediately after ASIC raised concerns in 2016, cooperated and agreed to resolve the matter, that these were the first contraventions alleged against it and that no client loss was alleged; the court allegedly approved the jointly proposed penalty.

Published

19 Dec 2025

Original amount 925,000 AUD, converted at the ECB reference rate of 18 Dec 2025.

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

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).

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 28 Sep 2026 · Version 2 · Direct link

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

Authority / court

Controladoria-Geral da União (CGU)

Area of law

Bribery and corruption

Legal basis

Lei nº 12.846/2013, Art. 5 II und V, Art. 6 I und II, Art. 14

Action

Fine

Status of proceedings

unknown

Sector

Financial services and insurance

Liability of senior managers

Measures against individuals are not set out here.

Published

2 Oct 2025

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

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

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

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

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

Authority / court

Controladoria-Geral da União (CGU) und Advocacia-Geral da União (AGU)

Area of law

Bribery and corruption · Bribery of public officials

Legal basis

Lei nº 12.846/2013, Art. 5 I, III und IV d, Art. 16; Lei nº 8.666/1993, Art. 88 II und III; Lei nº 8.429/1992

Action

Fine

Status of proceedings

final

Sector

Manufacturing and mechanical engineering

Mitigating circumstances

Commitment by the CGU and AGU to avoid double payments in relation to an agreement with the MPF; obligation to improve the integrity programme.

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

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

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.

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

The Minnesota provider of outpatient addiction treatment pays USD 18,500,000 to resolve False Claims Act allegations and entered into a five-year Corporate Integrity Agreement with HHS-OIG. According to the US Attorney's Office, from January 2019 to February 2025 NUWAY compensated Medicaid patients for attending intensive outpatient treatment and also billed services in which the same period of time was counted twice. The authority allegedly made the findings set out here; this account is not based on a final judgment.

Authority / court

U.S. Attorney's Office, District of Minnesota (U.S. Department of Justice)

Area of law

Bribery and corruption · Gifts, hospitality and benefits

Legal basis

False Claims Act; Anti-Kickback Statute

Action

Other

Status of proceedings

final

Sector

Healthcare

Published

26 Jun 2025

Original amount 18,500,000 USD, converted at the ECB reference rate of 26 Jun 2025.

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

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.

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

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

Authority / court

Controladoria-Geral da União (CGU) und Advocacia-Geral da União (AGU)

Area of law

Bribery and corruption · Bribery of public officials

Legal basis

Lei 12.846/2013, Art. 6 I, Arts. 16 und 17; Lei 8.429/1992, Art. 12; Decreto 11.129/2022

Action

Fine

Status of proceedings

final

Sector

Food and agriculture

Mitigating circumstances

Credit was given for returning the advantage (1%), cooperation (1%), voluntary admission (1.5%) and an applied compliance programme (2.1%).

Liability of senior managers

Tolerance or knowledge by management (3%) and the concurrence of several offences (3%) were aggravating factors.

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

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

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.

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.

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

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

Authority / court

Controladoria-Geral da União (CGU) und Advocacia-Geral da União (AGU)

Area of law

Bribery and corruption · Bribery of public officials

Legal basis

Lei nº 12.846/2013, Art. 5 I und III, Art. 16; Lei nº 8.429/1992; Decreto nº 11.129/2022

Action

Fine

Status of proceedings

final

Sector

Energy and utilities

Mitigating circumstances

Coordination with the US proceedings so that part of the Brazilian payment can be credited against the US fine; obligation to improve the integrity programme under CGU monitoring for 36 months.

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

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

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

Authority / court

Controladoria-Geral da União (CGU) und Advocacia-Geral da União (AGU)

Area of law

Bribery and corruption · Bribery of public officials

Legal basis

Lei 12.846/2013, Art. 6 I, Arts. 16 und 17, Art. 19 I; Lei 8.429/1992; Decreto 11.129/2022

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Mitigating circumstances

Credit was given for returning the advantage (1%), cooperation (1.5%) and voluntary admission (2%); no compliance programme was taken into account. The fine equals the statutory minimum of the advantage obtained, then reduced by 40%.

Liability of senior managers

Tolerance or knowledge by senior management was applied as an aggravating factor at the maximum rate of 3%.

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

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

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.

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