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

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

Between 2009 and 2011, more than 4 million EUR and more than 600,000 USD were paid to an official in Angola 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). 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

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 28 Sep 2026 · Version 3 · Direct link

Pfizer pays USD 59,746,277 on behalf of its subsidiary Biohaven to resolve False Claims Act and Anti-Kickback Statute allegations relating to the period before the acquisition; about USD 50.2 million goes to the federal government and about USD 9.5 million to state Medicaid programmes. From March 2020 to September 2022 Biohaven allegedly gave selected doctors speaker fees and meals at expensive restaurants to encourage prescriptions of the migraine drug Nurtec ODT; some events were attended repeatedly by the same doctors or by spouses, relatives and practice colleagues with no educational need.

Authority / court

U.S. Department of Justice (Civil Division; USAO Western District of New York)

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

Chemicals and pharmaceuticals

Employees

10,000 or more

Published

24 Jan 2025

Original amount 59,746,277 USD, converted at the ECB reference rate of 24 Jan 2025.

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

Bard and three affiliated companies pay USD 17 million to resolve allegations under the federal False Claims Act and several state statutes. Between 2016 and February 2020 they allegedly gave urology practices discounts, excessive free samples and savings on office supplies so that they would prescribe intermittent catheters by default using Bard's own “Link” prescription form; no liability was determined.

Authority / court

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

Area of law

Bribery and corruption · Gifts, hospitality and benefits

Legal basis

False Claims Act; Anti-Kickback Statute (42 U.S.C. § 1320a-7b); False-Claims-Gesetze mehrerer Bundesstaaten

Action

Other

Status of proceedings

final

Sector

Healthcare

Published

23 Jan 2025

Original amount 17,000,000 USD, converted at the ECB reference rate of 23 Jan 2025.

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

The Controladoria-Geral da União (CGU, Office of the Comptroller General) imposed on the Associação da Irmandade da Santa Casa de Misericórdia de Pacaembu, an association operating as a healthcare social organisation (Organização Social), a fine of BRL 47,391,386.87, extraordinary publication of the decision and a declaration of unsuitability for public contracts. According to the final report, the association rigged the selection procedure for managing the Hangar field hospital in Belém (Pará), committed fraud in performing the management contract for a regional hospital in Belém and used front persons and companies to conceal its real interests.

Authority / court

Controladoria-Geral da União (CGU)

Area of law

Bribery and corruption

Legal basis

Lei nº 12.846/2013, Art. 5 III und IV b und d, Art. 6, Art. 14; Lei nº 8.666/1993, Art. 87 IV und Art. 88 II und III

Action

Fine

Status of proceedings

final

Sector

Healthcare

Liability of senior managers

Measures against individuals are not set out here.

Published

28 Jan 2025

Original amount 47,391,386.87 BRL, converted at the ECB reference rate of 23 Jan 2025.

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

The Puerto Rico Medicare Advantage provider pays USD 15,228,340 to resolve False Claims Act and Anti-Kickback Statute allegations and entered into a five-year Corporate Integrity Agreement with HHS-OIG. From January 2018 to December 2022 MMM allegedly gave gift cards to administrative assistants of medical practices so that they would get thousands of Medicare beneficiaries to enrol in an MMM plan; the resulting premium payments amounted to USD 6,091,336.

Authority / court

U.S. Attorney's Office, District of Puerto Rico; HHS Office of Inspector General (HHS-OIG)

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

Financial services and insurance

Mitigating circumstances

The company's cooperation and its implementation of internal controls were taken into account.

Published

23 Dec 2024

Original amount 15,228,340 USD, converted at the ECB reference rate of 23 Dec 2024.

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

According to the SEC's findings, AAR paid sham commissions to public officials through intermediaries (a sales agent and a joint venture partner) 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.

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 28 Sep 2026 · Version 4 · Direct link

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.

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

The Californian hospital pays USD 10,250,000 (USD 9,518,954 to the federal government, USD 731,046 to the State of California) and entered into a five-year Corporate Integrity Agreement with HHS-OIG. The allegations were that it paid doctors who decided on inpatient admissions bonuses based on the number of patients admitted, billed medically unnecessary inpatient admissions and used false diagnosis codes for SIRS. 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, Eastern District of California (U.S. Department of Justice)

Area of law

Bribery and corruption · Commercial bribery

Legal basis

False Claims Act; Anti-Kickback Statute

Action

Other

Status of proceedings

final

Sector

Healthcare

Published

12 Dec 2024

Original amount 10,250,000 USD, converted at the ECB reference rate of 12 Dec 2024.

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

The South African subsidiary of McKinsey & Company entered into a three-year DPA with a penalty of USD 122,850,000; up to half is credited against payments to South African authorities. According to the Department, between at least 2012 and 2016 it obtained confidential information from two South African state-owned companies (logistics and energy) on consulting contracts and bid knowing that South African partner firms would pass part of their fees on to officials as bribes. According to the Department, the profit from the scheme was about USD 85 million.

Authority / court

U.S. Department of Justice (Criminal Division, Fraud Section; USAO Southern District of New York)

Area of law

Bribery and corruption · Bribery of public officials

Legal basis

Foreign Corrupt Practices Act (FCPA): Verschwörung zum Verstoß gegen die Anti-Bribery-Vorschriften (Criminal Information, Southern District of New York)

Action

Fine

Status of proceedings

unknown

Sector

Other

Mitigating circumstances

Credit was given for immediate, proactive cooperation, reporting of discovered attempts to delete records, personnel consequences, additional anti-corruption training in Africa and a temporary halt to work for state-owned enterprises.

Liability of senior managers

Measures against individuals are not reported here.

Published

5 Dec 2024

Original amount 122,850,000 USD, converted at the ECB reference rate of 5 Dec 2024.

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

The company entered into a three-year DPA; under the guidelines USD 54 million would have been appropriate, but because of a demonstrated inability to pay a penalty of USD 10 million was agreed, of which up to USD 4 million is credited against the SEC civil penalty. From 2017 to 2019 the company, then trading as 500.com, agreed to pay about USD 1.9 million to consultants, intended to reach Japanese officials as cash, travel, entertainment and gifts, in order to win an integrated resort bid in Japan; the payments were booked as consultancy fees under sham contracts. The authority allegedly made the findings set out here; this account is not based on a final judgment.

Authority / court

U.S. Department of Justice (Criminal Division, Fraud Section; USAO District of New Jersey)

Area of law

Bribery and corruption · Bribery of public officials

Legal basis

Foreign Corrupt Practices Act (FCPA): Verschwörung zum Verstoß gegen die Anti-Bribery- und Books-and-Records-Vorschriften sowie Verstoß gegen die Books-and-Records-Vorschriften (Criminal Information, District of New Jersey)

Action

Fine

Status of proceedings

final

Sector

Other

Mitigating circumstances

The penalty was capped at USD 10 million because of the company's financial condition; limited, reactive cooperation and remediation were credited (10% reduction off the bottom of the guidelines range).

Liability of senior managers

Measures against individuals are not set out here.

Published

18 Nov 2024

Original amount 10,000,000 USD, converted at the ECB reference rate of 18 Nov 2024.

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

The US company Freepoint Commodities LLC admitted, in a leniency agreement with the CGU and the AGU, to having paid undue advantages to public officials through intermediaries (Art. 5 I and III Lei 12.846/2013) and allegedly pays BRL 108,710,739.68 as a fine plus disgorgement. According to Annex III, BRL 60,919,037.14 is the fine payable to the Union (after a 67% reduction) and BRL 47,791,702.54 is disgorgement. Damages to Petrobras of BRL 22,542,907.62 are set out only in the text. The agreement also stated a total of BRL 131,253,647.32 (USD 22,744,839.85); the two centavos by which that total exceeds the fine, the disgorgement and the damages are not smoothed. If the company resumes business in Brazil within five years, it must adapt its compliance programme to Brazilian law and report to the CGU. 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. 5 I und III, Art. 6 I, Arts. 16, 17 und 19 I; Lei 8.429/1992; Decreto 11.129/2022

Action

Fine

Status of proceedings

final

Sector

Energy and utilities

Mitigating circumstances

Credit was given for remediation of damage (1%), cooperation (1.5%) and voluntary admission (2%); no reduction was granted for a compliance programme.

Liability of senior managers

Tolerance or knowledge by management was applied as an aggravating factor at 2.5%.

Original amount 108,710,739.68 BRL, converted at the ECB reference rate of 14 Nov 2024.

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

The Venezuelan subsidiary of Spain's Telefónica S.A. entered into a DPA and pays a penalty of USD 85,260,000. To be allowed to exchange bolívares for US dollars in a state currency auction in 2014, it had two suppliers pay about USD 28.9 million to an intermediary, part of which went to Venezuelan officials, and covered the cost through overpriced equipment purchases from those suppliers. It received more than USD 110 million from the auction, over 65% of the funds awarded. The authority allegedly made the findings set out here; this account is not based on a final judgment.

Authority / court

U.S. Department of Justice (Criminal Division, Fraud Section; USAO Southern District of New York)

Area of law

Bribery and corruption · Bribery of public officials

Legal basis

Foreign Corrupt Practices Act (FCPA): Verschwörung zum Verstoß gegen die Anti-Bribery-Vorschriften (Criminal Information, Southern District of New York)

Action

Fine

Status of proceedings

final

Sector

Telecoms, IT and software

Mitigating circumstances

Cooperation (initially diminished by late production of records) and remediation were credited: disciplinary action including dismissals, an independent compliance function with a Chief Compliance Officer, review of all non-standard pricing transactions, tighter third-party controls; 20% reduction.

Published

8 Nov 2024

Original amount 85,260,000 USD, converted at the ECB reference rate of 8 Nov 2024.

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

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 28 Sep 2026 · Version 3 · Direct link

From 2020 to 2022, employees of the Indian subsidiary of a US aerospace and defence supplier bribed Indian public officials via agents and distributors, among other things to tailor tenders in the group'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 28 Sep 2026 · Version 3 · Company name anonymised since 11 Oct 2026 · Direct link

From 2017 to 2020, the acquired Thai subsidiary provided public officials, including officials of the Royal Thai Air Force and the Department of Highways, with cash, sham consultancy fees, luxurious "factory visit trips", meals and entertainment, and also engaged in commercial bribery. The group is paying 4,343,401 USD in disgorgement, 1,086,954 USD in interest and a penalty of 4.5 million USD.

Authority / court

U.S. Securities and Exchange Commission (SEC)

Area of law

Bribery and corruption · Gifts, hospitality and benefits

Legal basis

FCPA Buchführungs- und interne Kontrollvorschriften (Sections 13(b)(2)(A)/(B) Exchange Act)

Action

Fine

Status of proceedings

final

Sector

Manufacturing and mechanical engineering

Employees

10,000 or more

Culpability

intentional

Published

10 Sep 2024

Original amount 9,930,355 USD, converted at the ECB reference rate of 10 Sep 2024.

Checked against the official source on 28 Sep 2026 · Version 5 · Company name anonymised since 10 Sep 2026 · Direct link

The group 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 28 Sep 2026 · Version 4 · Company name anonymised since 5 Aug 2026 · Direct link

The dialysis group allegedly paid kickbacks to promote referrals to its former pharmacy subsidiary and granted benefits to nephrologists and vascular surgeons to induce them to send patients to the group's dialysis centres. The group paid 34,487,390 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

Employees

10,000 or more

Original amount 34,487,390 USD, converted at the ECB reference rate of 18 Jul 2024.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 18 Jul 2026 · Direct link

Three home health agencies in Texas, Ohio and Indiana and their parent company allegedly granted kickbacks to assisted living facilities and physicians for Medicare referrals. They paid 4,496,330 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

Original amount 4,496,330 USD, converted at the ECB reference rate of 1 Jul 2024.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 1 Jul 2026 · Direct link

The CGU imposed fines totalling BRL 8,143,459.20 on a Brazilian retailer (BRL 4,386,459.20) and the group's jointly liable holding company (BRL 930,000.00) because, through an intermediary company, they had appropriated public funds stemming from tax relief (Art. 5 III Lei 12.846/2013), and on two project sponsors (BRL 1,297,000.00, Art. 5 II Lei 12.846/2013, and BRL 1,530,000.00 respectively); all four also breached the Lei Rouanet (Lei 8.313/1991, cultural incentive law), and three of them must additionally publish the decision by way of extraordinary publication. According to the final report, funded cultural projects (Pronacs) were diverted to produce books as marketing material for the retailer; a natural person was additionally fined BRL 500,000.00. On 30 September 2025 the CGU credited payments made by the retailer under a civil non-prosecution agreement (BRL 3,071,819.19 remaining) and rejected the requests of the holding company and the first project sponsor.

Authority / court

Controladoria-Geral da União (CGU)

Area of law

Bribery and corruption

Legal basis

Lei 12.846/2013, Art. 5 II und III, Art. 6 I und II; Lei 8.313/1991 (Lei Rouanet), Art. 2 §§ 1 und 2, Art. 23 § 1, Art. 38; Decreto 11.129/2022

Action

Fine

Status of proceedings

final

Sector

Retail and e-commerce

Mitigating circumstances

Payments made by the retailer under a civil non-prosecution agreement (ANPC) on the same facts were credited against its fine.

Published

21 Jun 2024

Original amount 8,143,459.2 BRL, converted at the ECB reference rate of 18 Jun 2024.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 18 Jun 2026 · Direct link

Three Norwegian shipping companies acknowledged, in a leniency agreement with the CGU and the AGU, that a commission they paid was partly used by third parties to fund bribes to a public official and gave them financial advantages in performing contracts with the public administration. Together they pay BRL 153,184,045.95: BRL 16,055,700.00 in damages and BRL 124,662,133.17 as return of the undue advantage to the injured subsidiary of a state-controlled group, plus a fine of BRL 12,466,212.78 under Lei 8.429/1992 payable to the Union.

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 8.666/1993, Art. 88 II und III; Lei 8.429/1992, Art. 9 i. V. m. Art. 3; Lei 12.846/2013, Arts. 16 und 17; Decreto 11.129/2022

Action

Disgorgement of profits

Status of proceedings

final

Sector

Transport, logistics and shipping

Original amount 153,184,045.95 BRL, converted at the ECB reference rate of 13 Jun 2024.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 13 Jun 2026 · Direct link

The Utah manufacturer of spinal implants allegedly paid surgeons kickbacks to induce them to use the manufacturer's products. The settlement of 12 million USD is a joint payment by the company and other settling parties; HHS-OIG placed the company under heightened scrutiny.

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 12,000,000 USD, converted at the ECB reference rate of 29 May 2024.

Checked against the official source on 28 Sep 2026 · Version 6 · Company name anonymised since 29 May 2026 · Direct link

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 the trading house 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 28 Sep 2026 · Version 4 · Company name anonymised since 1 Mar 2026 · Direct link

The Controladoria-Geral da União (CGU, Office of the Comptroller General) imposed on a healthcare services company a fine of BRL 21,697,740.49, extraordinary publication of the decision and a declaration of unsuitability for public contracts. According to the final report, in Ministry of Health tenders for medicines for rare diseases (Aldurazyme, Myozyme, Fabrazyme) the company had submitted bids without being authorised to market these products, failed to deliver the agreed quantities on time and appropriated advance payments to the detriment of the Treasury. The CGU rejected its request for reconsideration on 15 June 2025.

Authority / court

Controladoria-Geral da União (CGU)

Area of law

Bribery and corruption

Legal basis

Lei nº 12.846/2013, Art. 5 IV b und d, Art. 6; Lei nº 8.666/1993, Art. 87 IV und Art. 88 II und III

Action

Fine

Status of proceedings

final

Sector

Healthcare

Published

12 Jan 2024

Original amount 21,697,740.49 BRL, converted at the ECB reference rate of 9 Jan 2024.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 9 Jan 2026 · Direct link

The Controladoria-Geral da União (CGU, Office of the Comptroller General) imposed on a pharmaceutical distributor, which now trades under a different name, a fine of BRL 3,879,251.35, extraordinary publication of the decision and a declaration of unsuitability for public contracts (declaração de inidoneidade). According to the final report, in the Ministry of Health's planned purchase of 20 million doses of a Covid-19 vaccine the company submitted a document that the vaccine manufacturer later described as false, as well as pro forma invoices that did not match the contract terms. On a request for reconsideration (pedido de reconsideração) the CGU reduced the fine to BRL 2,586,167.56 on 5 May 2025 and shortened the posting period for the publication from 75 to 60 days; the declaration of unsuitability remained in place.

Authority / court

Controladoria-Geral da União (CGU)

Area of law

Bribery and corruption

Legal basis

Lei nº 12.846/2013, Art. 5 IV b und d, Art. 6; Lei nº 8.666/1993, Art. 87 IV und Art. 88 III

Action

Fine

Status of proceedings

reduced

Sector

Chemicals and pharmaceuticals

Mitigating circumstances

Following the request for reconsideration, the CGU reduced the fine from BRL 3,879,251.35 to BRL 2,586,167.56.

Published

15 Jan 2024

Original amount 2,586,167.56 BRL, converted at the ECB reference rate of 9 Jan 2024.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 9 Jan 2026 · Direct link

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.

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

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.

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

A Brazilian IT company acknowledged to the CGU and the AGU that it had booked funds irregularly in order to pay undue advantages to public officials or politicians and had thereby obtained advantages in contracts with the public administration (Art. 5 I–IV Lei 12.846/2013). The total debt of BRL 27,178,868.56 comprises compensation to an injured company (BRL 4,875,501.13) and to the health fund of the State of Santa Catarina (BRL 17,587,259.86) plus an anti-corruption fine of BRL 4,716,107.57. Because earlier agreements with the Federal Public Prosecutor's Office and the state comptroller CGE/SC are credited, only the fine payable to the Union remains outstanding.

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–IV, Arts. 16 und 17; Lei 8.429/1992; Decreto 11.129/2022

Action

Disgorgement of profits

Status of proceedings

final

Sector

Telecoms, IT and software

Mitigating circumstances

Credit was given for restitution or compensation (1%), cooperation (1.5%), voluntary admission (2%) and an applied compliance programme (2.4%).

Liability of senior managers

Tolerance by senior management was applied as an aggravating factor at 3%.

Original amount 27,178,868.56 BRL, converted at the ECB reference rate of 4 Dec 2023.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 4 Dec 2025 · Direct link

From at least 2012 to 2017, the group's Chinese majority-owned subsidiary 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; the group 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 28 Sep 2026 · Version 4 · Company name anonymised since 28 Sep 2025 · Direct link

From 2014 to 2018, employees of the group's Chinese subsidiary invited healthcare officials of state-owned customers abroad to purported conferences and training courses that in reality often consisted of sightseeing and entertainment; payment was made via a complicit travel agency. Payment of 3,538,897 USD in disgorgement, 1,042,721 USD in interest and a penalty of 2 million USD.

Authority / court

U.S. Securities and Exchange Commission (SEC)

Area of law

Bribery and corruption · Gifts, hospitality and benefits

Legal basis

FCPA Buchführungs- und interne Kontrollvorschriften

Action

Fine

Status of proceedings

final

Sector

Healthcare

Employees

10,000 or more

Culpability

intentional

Mitigating circumstances

Prompt self-report upon becoming aware, cooperation (including witnesses and documents) and extensive remedial measures.

Published

25 Aug 2023

Original amount 6,581,618 USD, converted at the ECB reference rate of 25 Aug 2023.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 25 Aug 2025 · Direct link

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.

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

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.

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

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.

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

Between 2006 and 2018, the company allegedly bribed Philippine public officials and defrauded the Philippine state in connection with a ballistic identification system for the national police. The four-year remediation agreement, approved by the Superior Court of Quebec in early 2023 and published on 16 May 2023, provides for a penalty of 6,593,178 CAD, a surcharge of 659,318 CAD and forfeiture of 3,296,589 CAD, as well as an independent monitor.

Authority / court

Public Prosecution Service of Canada (PPSC); Superior Court of Quebec

Area of law

Bribery and corruption · Bribery of public officials

Legal basis

s. 3 Corruption of Foreign Public Officials Act; s. 380 Criminal Code; Remediation Agreement (Part XXII.1 Criminal Code)

Action

Fine

Status of proceedings

final

Sector

Defence and security

Culpability

intentional

Published

17 May 2023

Original amount 10,549,085 CAD, converted at the ECB reference rate of 16 May 2023.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 16 May 2025 · Direct link

From 2014 to 2019, employees, distributors and sub-distributors of the group's Chinese subsidiary improperly influenced the technical specifications of public hospital tenders and organised sham bids with products from other manufacturers; special discounts to distributors also created the risk that inflated margins financed payments to employees of state-owned hospitals. Payment of 41,126,170 USD in disgorgement, 6,047,633 USD in interest and a penalty of 15 million USD; the group had already been sanctioned in 2013 for similar conduct in Poland.

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

Action

Fine

Status of proceedings

final

Sector

Healthcare

Employees

10,000 or more

Culpability

intentional

Repeat case

yes

Published

11 May 2023

Original amount 62,173,803 USD, converted at the ECB reference rate of 11 May 2023.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 11 May 2025 · Direct link

Because of deficiencies in corporate governance, risk management and compliance, employees of a Swiss security technology provider were able to bribe public officials in connection with business in Brazil, Colombia and Venezuela. The Bundesanwaltschaft (BA, Office of the Attorney General of Switzerland) convicted the company by summary penalty order and imposed a fine of CHF 1,000,000 and a compensatory claim of CHF 80,000,000, CHF 81 million in total. The penalty order against the company is final because the company waived its right to object.

Authority / court

Bundesanwaltschaft (BA)

Area of law

Bribery and corruption · Bribery of public officials

Legal basis

Art. 102 Abs. 2 StGB i.V.m. Art. 322septies StGB; Ersatzforderung nach Art. 71 Abs. 1 StGB

Action

Fine

Status of proceedings

final

Sector

Other

Published

27 Apr 2023

Original amount 81,000,000 CHF, converted at the ECB reference rate of 27 Apr 2023.

Checked against the official source on 2 Oct 2026 · Company name anonymised since 27 Apr 2025 · Direct link

The Controladoria-Geral da União (CGU, Office of the Comptroller General) set a fine of BRL 22,423,482.15 against a carmaker in an early resolution procedure (julgamento antecipado) under the cultural incentive law (Lei nº 8.313/1991) and the Anti-Corruption Law. The carmaker had sponsored with BRL 1,000,000 a concert project funded through the National Culture Support Programme (Pronac), which was turned, without the consent of the Ministry of Culture, into a corporate party for the company's 60th anniversary that was not open to the public; according to the final report, false information was given in the project accounts. A separate decision issued the same day fined the project's proponent BRL 2,940,317.28.

Authority / court

Controladoria-Geral da União (CGU)

Area of law

Bribery and corruption

Legal basis

Lei nº 8.313/1991, Art. 38; Lei nº 12.846/2013, Art. 5 II und Art. 6; Portaria Normativa CGU nº 19/2022

Action

Fine

Status of proceedings

final

Sector

Automotive

Employees

10,000 or more

Mitigating circumstances

The CGU took into account the company's cooperation and commitments and decided in the early resolution procedure under Portaria Normativa CGU nº 19/2022 (CGU regulatory ordinance).

Published

10 Feb 2023

Original amount 22,423,482.15 BRL, converted at the ECB reference rate of 9 Feb 2023.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 9 Feb 2025 · Direct link

A Brazilian food group undertook, in a leniency agreement with the CGU (Office of the Comptroller General) and the AGU (Office of the Attorney General), to pay BRL 583,977,360.48 in five annual instalments from 2023 because, according to the confidential Annex I, it had paid undue advantages to public officials or third parties connected to them. The amount comprises disgorgement of unlawful advantages (BRL 314,875,384.01), a fine under Lei 8.429/1992 (BRL 9,173,587.96) and a fine under the Anti-Corruption Act Lei 12.846/2013 (BRL 259,928,388.50); without the agreed reductions it would have been BRL 1,170,184,567.12. According to the agreement, the conduct did not concern federal procurement and no damage to the public purse had been established by the time of signing.

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, Arts. 16 und 17; Lei 8.429/1992; Decreto 11.129/2022, Art. 33; Instrução Normativa CGU/AGU 2/2018

Action

Disgorgement of profits

Status of proceedings

final

Sector

Food and agriculture

Employees

10,000 or more

Mitigating circumstances

Cooperation (1%), spontaneous disclosure before proceedings (1%) and an applied compliance programme (2.21%) were credited; the anti-corruption fine was reduced by 63.33% and the disgorgement by 30%.

Liability of senior managers

Tolerance or knowledge by senior management was applied as an aggravating factor at 2.25%.

Original amount 583,977,360.48 BRL, converted at the ECB reference rate of 28 Dec 2022.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 28 Dec 2024 · Direct link

A Singapore-based offshore and shipyard group 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 payments to public officials and intermediaries in contractual relationships with the public administration. The agreed global value covering damages, fines and other penalties is BRL 1,223,657,710.19; payments under the earlier agreement between its Brazilian subsidiary and the Federal Public Prosecutor's Office (MPF) may be credited. This followed a global resolution in December 2017 with authorities in the United States, Singapore and Brazil totalling USD 422,216,980, of which USD 211,108,490 went to the state-controlled oil company and the Federal Union.

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. 16; Lei nº 8.429/1992; Decreto nº 11.129/2022

Action

Fine

Status of proceedings

final

Sector

Manufacturing and mechanical engineering

Mitigating circumstances

Crediting of payments made under the agreement with the MPF; obligation to improve the integrity programme.

Original amount 1,223,657,710.19 BRL, converted at the ECB reference rate of 19 Dec 2022.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 19 Dec 2024 · Direct link

A US chemical and technology company undertook, in 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), to pay BRL 638,046,365.87 (equivalent to USD 120,828,384.25) because, in connection with contracts with a state-controlled oil company, it had made improper payments for the benefit of public officials through intermediary companies. According to the annexes, USD 75,817,531.39 relates to disgorgement of profit and USD 10,601,873.74 to presumed damage (bribes) in favour of the oil company, while USD 5,708,217.91 is the fine under the Anti-Corruption Act (Lei 12.846/2013) and USD 28,700,761.19 the fine under the Administrative Improbity Act (Lei 8.429/1992). According to its own statement, the company concluded agreements with the Federal Public Prosecutor's Office (MPF), the US Department of Justice and the SEC on the same day.

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, Arts. 16 und 17; Lei 8.429/1992; Decreto 11.129/2022, Art. 33

Action

Disgorgement of profits

Status of proceedings

final

Sector

Chemicals and pharmaceuticals

Mitigating circumstances

Credit was given for remediation of damage (1%), cooperation (1%), voluntary admission (2%) and an applied compliance programme (3.06%).

Liability of senior managers

The fine calculation treated tolerance or knowledge by senior management as an aggravating factor at the maximum rate of 3%.

Original amount 638,046,365.87 BRL, converted at the ECB reference rate of 19 Dec 2022.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 19 Dec 2024 · Direct link

From 2013 employees of an electrical engineering group set up a bribery scheme in which inflated payments to subcontractors were used to channel benefits to public officials in South Africa and win contracts for the construction of a coal-fired power station (bribes of at least CHF 1.3 million, contracts worth at least USD 200 million). By summary penalty order, the Bundesanwaltschaft (BA, Office of the Attorney General of Switzerland) convicted a Swiss services company of the group for failing to take all reasonable organisational measures to prevent this, fined it CHF 4,000,000 (statutory maximum CHF 5 million) and ordered it to pay procedural costs of CHF 50,000. The BA waived a compensatory claim because the group had already paid USD 104 million to South Africa in 2020.

Authority / court

Bundesanwaltschaft (BA)

Area of law

Bribery and corruption · Bribery of public officials

Legal basis

Art. 102 Abs. 2 StGB i.V.m. Art. 322septies StGB

Action

Fine

Status of proceedings

unknown

Sector

Manufacturing and mechanical engineering

Mitigating circumstances

Cooperation taken into account as mitigating; no compensatory claim because of a USD 104 million settlement payment already made to South Africa in 2020.

Published

2 Dec 2022

Original amount 4,000,000 CHF, converted at the ECB reference rate of 2 Dec 2022.

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

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.

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

With the company's approval, agents and employees of the London oil trading division paid more than 25 million USD in bribes for preferential access to oil in Nigeria, Cameroon, Côte d'Ivoire, Equatorial Guinea, Ghana, South Sudan and Malawi. Following guilty pleas to seven counts, the court imposed fines of 182,935,392 GBP and a confiscation order of 93,479,338.95 GBP (276,414,730.95 GBP in total), plus 4,550,362 GBP in costs.

Authority / court

Serious Fraud Office (SFO); Southwark Crown Court

Area of law

Bribery and corruption · Bribery of public officials

Legal basis

Bribery Act 2010, s. 1 (fünf Fälle) und s. 7 (zwei Fälle); Proceeds of Crime Act 2002 (Confiscation)

Action

Fine

Status of proceedings

final

Sector

Energy and utilities

Employees

10,000 or more

Culpability

intentional

Published

3 Nov 2022

Original amount 276,414,730.95 GBP, converted at the ECB reference rate of 3 Nov 2022.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 3 Nov 2024 · Direct link

The CGU imposed on a Brazilian engineering and construction company a fine of BRL 36,363,406.20, extraordinary publication of the decision and a declaration of unfitness for public contracts until rehabilitation. The basis was the frustration of competition in a state-owned nuclear power operator's tenders for the electromechanical assembly of a nuclear power plant through agreements with competitors (Art. 5 IV Lei 12.846/2013); the Minister considered the bribery allegation (Art. 5 I) insufficiently proven. The CGU rejected the request for reconsideration on 8 April 2024.

Authority / court

Controladoria-Geral da União (CGU)

Area of law

Bribery and corruption

Legal basis

Lei 12.846/2013, Art. 5 IV, Art. 6 I und II; Lei 8.666/1993, Art. 87 IV i. V. m. Art. 88 III; Decreto 8.420/2015

Action

Fine

Status of proceedings

final

Sector

Construction and real estate

Published

14 Oct 2022

Original amount 36,363,406.2 BRL, converted at the ECB reference rate of 11 Oct 2022.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 11 Oct 2024 · Direct link

According to the order of the Securities and Exchange Commission (SEC, the US securities regulator), subsidiaries in Turkey, the United Arab Emirates and India created off-book slush funds from 2016 to 2019, which were used to bribe foreign officials; in Turkey and the UAE they also financed conference trips for officials, in Turkey partly with family members or side trips to California. The group pays 7,114,376 USD in disgorgement, 791,040 USD in interest and a 15 million USD penalty (together 22,905,417 USD); it is already the second SEC proceeding, following a 2012 settlement over side funds in India.

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 (Antibestechungs-, Buchführungs- und interne Kontrollvorschriften)

Action

Fine

Status of proceedings

final

Sector

Telecoms, IT and software

Employees

10,000 or more

Repeat case

yes

Published

27 Sep 2022

Original amount 22,905,416.64 USD, converted at the ECB reference rate of 27 Sep 2022.

Checked against the official source on 28 Sep 2026 · Version 3 · Company name anonymised since 27 Sep 2024 · Direct link

An airline entered into a leniency agreement (acordo de leniência) 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 payments to public officials or third parties connected to them, which it had self-reported in 2020. It pays a total of BRL 14,266,602.39, of which BRL 8,559,964.86 is the return of the undue advantages paid and BRL 5,706,637.53 a fine under the Administrative Improbity Law (Lei nº 8.429/1992). The agreement forms part of a coordinated global resolution with the US Department of Justice (DOJ) and the US Securities and Exchange Commission (SEC).

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 (Lei Anticorrupção); Lei nº 8.429/1992 (Lei de Improbidade Administrativa)

Action

Fine

Status of proceedings

final

Sector

Transport, logistics and shipping

Mitigating circumstances

Self-report in 2020 and effective cooperation, which according to the CGU led to mitigated sanctions; commitment to keep improving its integrity policies and control mechanisms.

Published

15 Sep 2022

Original amount 14,266,602.39 BRL, converted at the ECB reference rate of 15 Sep 2022.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 15 Sep 2024 · Direct link