Compliance Radar
Who was sanctioned, and for what?
Fines, court rulings and incidents from Europe, North America, Latin America, Asia-Pacific, Middle East and Africa: 2,207 cases from 44 jurisdictions, each with an official source and checked against that source before publication. Filter by country, area of law and sector. Click a chart to drill down one level.
Click a bar to drill down one level.
Where?
by regionAll jurisdictions
What for?
by action- Fine €2.43bn 91 % · 42 cases
- Disgorgement of profits €253.8m 9 % · 6 cases
Who?
by sectorAll sectors
- Energy and utilities €864.9m 32 % · 7 cases
- Manufacturing and mechanical engineering €381.4m 14 % · 8 cases
- Defence and security €357.3m 13 % · 3 cases
- Other €226.5m 8 % · 4 cases
- Telecoms, IT and software €210.6m 8 % · 5 cases
- Steel and metals €164.7m 6 % · 2 cases
- Food and agriculture €121.4m 5 % · 4 cases
- Chemicals and pharmaceuticals €113.3m 4 % · 1 case
- Transport, logistics and shipping €82.5m 3 % · 3 cases
- Construction and real estate €62.3m 2 % · 5 cases
- 3 more€95.7m
When?
per year, by date of decision| Period | Cases | Total |
|---|---|---|
| 2022 | 8 | €797.9m |
| 2023 | 9 | €421m |
| 2024 | 11 | €872.2m |
| 2025 | 11 | €495.2m |
| 2026 | 9 | €94.4m |
48 cases
17 Jul 2026 The Scoular CompanyAgricultural trader Scoular pays 10 million USD over bribes to Mexican border officials €8.91m
From 2013 to 2019, Scoular had customs brokers pay around 400,000 USD to Mexican border and inspection officials so that trains carrying contaminated maize and grain would pass inspections; some of the money went to individuals close to cartels. Three-year DPA with a criminal penalty of 9,769,521 USD and forfeiture of 414,351 USD.
Customs agents and freight forwarders are high-risk third parties: question conspicuous flat fees per shipment, even if they appear to be customary charges.
Facilitation payments via customs agents and logistics service providers
Missing or inadequate training played a role in the decision.
- Authority / court
- U.S. Department of Justice (Criminal Division, Fraud Section; USAO Western District of Texas)
- Area of law
- Bribery and corruption · Bribery of public officials
- Legal basis
- FCPA (Verschwörung zur Verletzung der Anti-Bestechungsvorschriften); Deferred Prosecution Agreement
- Action
- Fine
- Status of proceedings
- final
- Sector
- Food and agriculture
- Culpability
- intentional
- Mitigating circumstances
- Cooperation and remediation (including an overhaul of compliance, third-party management, financial controls and anti-corruption training); 25 % reduction off the low end of the sentencing guidelines range.
- Liability of senior managers
- 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.
- Agricultural Company to Pay Over $10M to Resolve Foreign Bribery Case Press release of an authority
- Deferred Prosecution Agreement, United States v. The Scoular Company, 3:26-cr-01685-KC (W.D. Tex.), filed 07/17/26 Decision of an authority
- DOJ Criminal Division: United States v. The Scoular Company (Fallseite) Enforcement database of an authority
Checked against the official source on 28 Sep 2026 · Version 3 · Direct link
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1 May 2026 Ultra Electronics Holdings Limited (vormals plc)Ultra Electronics: DPA of around 10.1 million GBP over bribery in Algeria and Oman €11.6m
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.
Companies that use agents for government contracts must be able to demonstrate adequate procedures – otherwise the company is liable under Section 7 Bribery Act even without any intent to bribe on its own part.
Use of sales agents in public contracts
- 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.
- SFO secures £10m from British defence supplier Press release of an authority
- SFO DPA with Ultra Electronics Holdings Limited (formerly plc) Decision of an authority
- Serious Fraud Office v Ultra Electronics Holdings [2026] EWCR 4 (Approved Judgment, 1 May 2026) Court decision
- SFO-Ultra Indictment (Crown Court at Southwark) Decision of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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19 Mar 2026 Colas Rail Asia Sdn Bhd (Colas-Gruppe)Colas Rail Asia: CJIP of 29.7 million EUR over bribery in metro contracts in Malaysia €29.7m
The Malaysian subsidiary of Colas Rail paid large, undocumented sums via intermediaries in connection with public contracts for urban rail lines in Kuala Lumpur (Kelana Jaya extension, MRT2). Following an internal investigation, Colas Rail self-reported the matter in 2017; the CJIP (Convention judiciaire d'intérêt public, a French deferred prosecution agreement) provides for a public interest fine of 29,745,974 EUR and a three-year compliance programme monitored by the French Anti-Corruption Agency (AFA) (costs of up to 1.9 million EUR).
Undocumented payments to intermediaries on foreign projects must be stopped early by the finance and compliance functions – self-reporting after an internal investigation is rewarded.
Intermediaries and consultants in public tenders
- Authority / court
- Parquet national financier (PNF); Validierung durch den Präsidenten des Tribunal judiciaire de Paris
- Area of law
- Bribery and corruption · Bribery of public officials
- Legal basis
- Art. 41-1-2 Code de procédure pénale (CJIP); Bestechung ausländischer Amtsträger
- Action
- Fine
- Status of proceedings
- final
- Sector
- Construction and real estate
- Employees
- 10,000 or more
- Culpability
- intentional
- Mitigating circumstances
- Self-report (criminal complaint filed by Colas Rail on 31 May 2017) following an internal forensic investigation.
- Liability of senior managers
- The CJIP does not address the criminal liability of natural persons.
- Published
- 19 Mar 2026
- Communiqué de presse du procureur de la République financier – CJIP COLAS RAIL ASIA Press release of an authority
- Convention judiciaire d'intérêt public – COLAS RAIL ASIA (17.03.2026) Decision of an authority
- Ministère de la Justice: Conventions judiciaires d'intérêt public (Verzeichnis) Official register or notice
Checked against the official source on 25 Sep 2026 · Direct link
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19 Mar 2026 Balt USA LLC (Balt-Gruppe)Balt USA: CJIP in France over payments to a hospital physician €1.77m
In parallel with the US declination, the PNF concluded a CJIP with the US subsidiary of the French medical technology manufacturer for 1,765,493 EUR (after crediting the US disgorgement) and a three-year AFA compliance programme. The case arose from Balt SAS's voluntary self-disclosure of 22 May 2023 concerning conduct at the acquired company Blockade Medical.
Acquisitions require anti-corruption due diligence on the target company – otherwise legacy misconduct by its management becomes a group risk.
Benefits to hospital physicians, integration of acquired companies
- Authority / court
- Parquet national financier (PNF); Validierung durch den Präsidenten des Tribunal judiciaire de Paris
- Area of law
- Bribery and corruption · Bribery of public officials
- Legal basis
- Art. 41-1-2 Code de procédure pénale (CJIP); aktive und passive Bestechung von Amtsträgern
- Action
- Fine
- Status of proceedings
- final
- Sector
- Healthcare
- Employees
- 250 to 999
- Culpability
- intentional
- Mitigating circumstances
- Voluntary self-disclosure to the PNF and the DOJ; coordinated resolution with crediting.
- Liability of senior managers
- The CJIP does not address the criminal liability of natural persons.
- Published
- 19 Mar 2026
- Communiqué de presse du procureur de la République financier – CJIP BALT USA Press release of an authority
- Ministère de la Justice – Conventions judiciaires d'intérêt public (Liste) Official register or notice
- CJIP Société BALT USA LLC (17.03.2026) Decision of an authority
Checked against the official source on 28 Sep 2026 · Version 2 · Direct link
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17 Mar 2026 Balt SAS / Balt USA LLCMedical technology: DOJ declination for Balt SAS after bribery of a hospital physician €1.05m
Through sham consultancy agreements, fictitious invoices and purported bonus payments, around 602,000 USD in bribes flowed from 2017 to 2023 via a Belgian consultant to a physician in a senior position at a French public hospital, so that the hospital would purchase embolisation coils from Balt. The DOJ declined to prosecute on account of voluntary self-disclosure, cooperation and remediation (declination of 17 March 2026); Balt is disgorging 1,214,797 USD in profits.
Physicians at public hospitals are public officials – consultancy agreements with them require documented services and approval by the compliance function.
Benefits to physicians in the public healthcare sector, sham consultancy agreements
- Authority / court
- U.S. Department of Justice (Criminal Division, Fraud Section)
- Area of law
- Bribery and corruption · Bribery of public officials
- Legal basis
- FCPA; Corporate Enforcement and Voluntary Self-Disclosure Policy (Declination)
- Action
- Disgorgement of profits
- Status of proceedings
- final
- Sector
- Healthcare
- Culpability
- intentional
- Mitigating circumstances
- Voluntary self-disclosure (including to the French national financial prosecutor's office, PNF), full cooperation, timely remediation, disciplinary measures, parallel resolution in France.
- Liability of senior managers
- 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.
- U.S. Department of Justice, Pressemitteilung zu Balt SAS (Entscheidung 2026) Press release of an authority
- Communiqué de presse du procureur de la République financier – CJIP BALT USA (19.03.2026) Press release of an authority
- DOJ Criminal Division, Fraud Section: Declination Letter Re: Balt SAS (17.03.2026) Decision of an authority
Checked against the official source on 28 Sep 2026 · Version 3 · Direct link
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6 Mar 2026 Fleurette Properties LtdCommodities holding Fleurette: 25.8 million EUR strafbeschikking over bribery in Congo €25.8m
According to the Dutch Public Prosecution Service (OM), the top holding company of a mining, oil and gold group, which was based in the Netherlands from 2010 to 2017, participated together with others in bribing public officials of the DR Congo in order to obtain licences for cobalt and copper mines. On 6 March 2026, the OM issued a strafbeschikking (prosecutorial penalty order) imposing a fine of 25.8 million EUR, which Fleurette accepted.
In the commodities sector, licences and concessions are the main target for bribery – holding companies share liability for payments made by their subsidiaries.
Award of licences in the commodities sector, payments to public officials
- Authority / court
- Openbaar Ministerie (OM); Ermittlungen FIOD Anti-Corruptie Centrum
- Area of law
- Bribery and corruption · Bribery of public officials
- Legal basis
- Buitenlandse ambtelijke omkoping (Wetboek van Strafrecht); OM-strafbeschikking
- Action
- Fine
- Status of proceedings
- final
- Sector
- Steel and metals
- Culpability
- intentional
- Published
- 10 Mar 2026
- Geldboete Fleurette Properties Ltd wegens omkoping in Congo Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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18 Feb 2026 Périphériques et Matériels de Contrôle SAS (Groupe Carrus)Betting terminal manufacturer PMC: CJIP over payments to an official in Mali €499,150
From 2008 to 2011, the Paris-based supplier of betting and gaming terminals made unjustified payments of 78,972 EUR to an official of a majority state-owned company in Mali, with which it had a supply contract awarded without a tender. The case was triggered by a report from TRACFIN (the French financial intelligence unit). Public interest fine of 499,150 EUR (including 335,000 EUR already seized) and a three-year AFA compliance programme.
Managers of state-controlled companies are also public officials – even small private payments to them create a risk of criminal liability for medium-sized companies.
Payments to heads of state-owned companies abroad
- Authority / court
- Parquet national financier (PNF); Validierung durch den Präsidenten des Tribunal judiciaire de Paris
- Area of law
- Bribery and corruption · Bribery of public officials
- Legal basis
- Art. 41-1-2 Code de procédure pénale (CJIP); Bestechung ausländischer Amtsträger und Geldwäsche
- Action
- Fine
- Status of proceedings
- final
- Sector
- Telecoms, IT and software
- Employees
- 50 to 249
- Culpability
- intentional
- Liability of senior managers
- The CJIP does not address the criminal liability of natural persons.
- Published
- 18 Feb 2026
- Communiqué de presse du procureur de la République financier – CJIP PMC Press release of an authority
- Convention judiciaire d'intérêt public – Périphériques et Matériels de Contrôle SAS Decision of an authority
- Ministère de la Justice: Conventions judiciaires d'intérêt public (Verzeichnis) Official register or notice
Checked against the official source on 28 Sep 2026 · Version 2 · Direct link
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10 Feb 2026 Strukton Civiel Projecten B.V. und Strukton International B.V. (Strukton-Gruppe)Construction group Strukton pays 10 million EUR out-of-court settlement over bribery on the Riyadh Metro €10m
To secure a share in the Riyadh Metro project, around 31 million USD was paid between 2013 and 2021 to an agent representing a high-ranking member of the Saudi royal family; the agent payments were understated to the export credit insurer Atradius. Strukton accepted a transaction (out-of-court settlement) of 10 million EUR.
Commissions to agents with ties to ruling families carry the highest risk – and false statements to export credit insurers constitute a second offence.
Agent commissions and false statements to export credit insurers
- Authority / court
- Openbaar Ministerie (OM)
- Area of law
- Bribery and corruption · Bribery of public officials
- Legal basis
- Buitenlandse ambtelijke omkoping und valsheid in geschrift (Wetboek van Strafrecht); Transactie nach Art. 74 Sr
- Action
- Fine
- Status of proceedings
- final
- Sector
- Construction and real estate
- Culpability
- intentional
- Mitigating circumstances
- Cooperation from mid-2023; compliance programme in place since 2017; the employees involved are no longer with the company.
- Published
- 30 Mar 2026
- Strukton betaalt hoge transactie van 10 miljoen euro na corruptieonderzoek Press release of an authority
- OM Functioneel Parket: Transactieovereenkomst Calisto (10.02.2026) Decision of an authority
- College van procureurs-generaal: Beslissing hoge transactie onderzoek Calisto (09.02.2026) Decision of an authority
Checked against the official source on 28 Sep 2026 · Version 2 · Direct link
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26 Jan 2026 JBJ Agropecuária Ltda., Prima Foods S.A.JBJ Agropecuária and Prima Foods: BRL 31.16m in fines under leniency agreement €4.98m
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.
Parallel agreements with prosecutors and oversight bodies can be coordinated – double payments are credited, but the liability remains.
Payment to a public official to influence official action
- 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.
- CGU/AGU – Acordo de Leniência com JBJ Agropecuária Ltda. e Prima Foods S.A. (Processo 00190.109011/2022-88) Decision of an authority
- Acordo de Leniência JBJ/Prima – Anexo II: Demonstrativo de cálculo e valor da multa Decision of an authority
- Acordo de Leniência JBJ/Prima – Anexo III: Demonstrativo do valor, imputação, cronograma e instrução de pagamento Decision of an authority
- CGU – Acordos de leniência celebrados (Liste) Official register or notice
Checked against the official source on 3 Oct 2026 · Direct link
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12 Nov 2025 Comunicaciones Celulares S.A. (TIGO Guatemala)TIGO Guatemala pays more than 118 million USD for bribing members of Congress €102.1m
From 2012 to 2018, the Guatemalan mobile network operator made monthly cash payments to members of Congress or their security staff in order to obtain legislative support; part of the funds came from laundered drug money. Two-year Deferred Prosecution Agreement with a criminal penalty of 60 million USD and administrative forfeiture of 58,198,343 USD.
In joint ventures with local partners, the parent company needs genuine control over cash flows and contacts with public officials – an early voluntary self-disclosure is no substitute for a full investigation.
Bribery of public officials, cash payments, integrity of co-shareholders
- Authority / court
- U.S. Department of Justice (Criminal Division, Fraud Section; USAO Southern District of Florida)
- Area of law
- Bribery and corruption · Bribery of public officials
- Legal basis
- FCPA, 15 U.S.C. § 78dd-3 (Verschwörung, 18 U.S.C. § 371); Deferred Prosecution Agreement
- Action
- Fine
- Status of proceedings
- final
- Sector
- Telecoms, IT and software
- Culpability
- intentional
- Mitigating circumstances
- Voluntary self-disclosure by the parent company Millicom in 2015; subsequently extensive cooperation and remediation (including dismissals of staff and an 800 % increase in compliance personnel).
- Published
- 12 Dec 2025
Original amount 118,198,343 USD, converted at the ECB reference rate of 12 Nov 2025.
- TIGO Guatemala Paid Over $118M to Resolve Foreign Bribery Investigation Press release of an authority
- Deferred Prosecution Agreement, United States v. Comunicaciones Celulares S.A. d/b/a TIGO Guatemala (Case 1:25-cr-20476) Decision of an authority
Checked against the official source on 28 Sep 2026 · Version 2 · Direct link
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3 Sep 2025 SURYS SAS (Gruppe Imprimerie Nationale)Hologram manufacturer SURYS: CJIP of 18.4 million EUR in the Ukrainian passport case €18.4m
From 2013, SURYS supplied security holograms for Ukrainian passports to the state-owned company Polygraph via an interposed Estonian company; the investigation (following a request for mutual legal assistance from Ukraine's National Anti-Corruption Bureau, NABU) concerned misappropriation of public funds, bribery of foreign public officials and money laundering. Public interest fine of 18,363,007 EUR, plus 3,770,000 EUR in damages to the Ukrainian state and a three-year AFA compliance programme.
If a state customer insists on an interposed trader without any discernible added value, treat this as a red flag for misappropriation and bribery.
Interposed trading companies and sales agents
- Authority / court
- Parquet national financier (PNF); Validierung durch den Präsidenten des Tribunal judiciaire de Paris
- Area of law
- Bribery and corruption · Bribery of public officials
- Legal basis
- Art. 41-1-2 Code de procédure pénale (CJIP); Bestechung ausländischer Amtsträger, Geldwäsche
- Action
- Fine
- Status of proceedings
- final
- Sector
- Other
- Employees
- 250 to 999
- Culpability
- intentional
- Liability of senior managers
- The CJIP does not address the criminal liability of natural persons.
- Published
- 3 Sep 2025
- Communiqué de presse du procureur de la République financier – CJIP SURYS Press release of an authority
- Convention judiciaire d'intérêt public – SURYS (08.07.2025) Decision of an authority
- Ministère de la Justice: Conventions judiciaires d'intérêt public (Verzeichnis) Official register or notice
Checked against the official source on 25 Sep 2026 · Direct link
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7 Aug 2025 Liberty Mutual Insurance CompanyLiberty Mutual: declination against 4.7 million USD after bribery of Indian state bank employees €4.04m
From 2017 to 2022, the Indian subsidiary Liberty General Insurance paid around 1.47 million USD to employees of six state-owned banks so that they would refer bank customers to its insurance products; the payments were booked as marketing expenses and routed through third parties. The DOJ declined to prosecute; Liberty Mutual is disgorging 4,699,088 USD in profits.
Employees of state-owned banks are public officials – sales commissions paid to them are bribes, even if they are booked as marketing.
Distribution partnerships with state-owned banks, payments disguised as marketing
- Authority / court
- U.S. Department of Justice (Fraud Section; USAO District of Massachusetts)
- Area of law
- Bribery and corruption · Bribery of public officials
- Legal basis
- FCPA, 15 U.S.C. § 78dd-2; Corporate Enforcement and Voluntary Self-Disclosure Policy (Declination)
- Action
- Disgorgement of profits
- Status of proceedings
- final
- Sector
- Financial services and insurance
- Employees
- 10,000 or more
- Culpability
- intentional
- Mitigating circumstances
- Voluntary self-disclosure (March 2024), full cooperation, root cause analysis, termination of those involved, improved controls including rules on messaging apps.
- Published
- 7 Aug 2025
Original amount 4,699,088 USD, converted at the ECB reference rate of 7 Aug 2025.
- DOJ Declination Letter – Liberty Mutual Insurance Company (07.08.2025) Decision of an authority
- DOJ Criminal Division: CEP Declinations Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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30 Jul 2025 Seatrium Ltd., Jurong Shipyard Pte. Ltd., Estaleiro Jurong Aracruz Ltda.Seatrium and Jurong: leniency agreement for BRL 728.9m €113.2m
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.
Companies with large public contracts must effectively prevent benefits to public officials, politicians and their associates, as authorities in several countries act in parallel.
Benefits to public officials and politically exposed persons
- 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
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27 Jun 2025 IDEMIA France (vormals Oberthur Technologies)Paris prosecutor: CJIP with IDEMIA France for €15.54m over foreign bribery €15.5m
IDEMIA France, formerly Oberthur Technologies, undertook to pay a public interest fine of 15,541,130 EUR in a CJIP (convention judiciaire d'intérêt public, French deferred prosecution agreement) with the Paris public prosecutor. The investigation opened in 2013, including for bribery of foreign public officials and money laundering, concerned contracts between the Angolan central bank (BNA) and Oberthur Technologies from its former banknote business; validation took place on 27 June 2025.
Contracts with state bodies such as central banks require particularly careful scrutiny of intermediaries and payment flows.
Bribery risks in contracts with state central banks
- Authority / court
- Parquet de Paris (Procureure de la République); Validierung durch das Tribunal judiciaire de Paris
- Area of law
- Bribery and corruption · Bribery of public officials
- Legal basis
- Art. 41-1-2 Code de procédure pénale (corruption d'agent public étranger, blanchiment)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Manufacturing and mechanical engineering
- Published
- 27 Jun 2025
- Communiqué de presse de la Procureure de la République de Paris, 27 juin 2025 (CJIP IDEMIA France) Press release of an authority
- Ministère de la Justice: Liste der Conventions judiciaires d'intérêt public Official register or notice
Checked against the official source on 2 Oct 2026 · Direct link
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5 May 2025 Minerva S.A.Minerva: BRL 22m fine under leniency agreement over advantages for public officials €3.44m
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.
A working compliance programme and early cooperation noticeably reduce the fine, but do not cancel out the effect of management responsibility.
Payments to public officials to influence official action
- 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.
- CGU/AGU – Acordo de Leniência com a Minerva S.A. (Processo 00190.102672/2022-82) Decision of an authority
- Acordo de Leniência Minerva – Anexo II: Demonstrativo de cálculo e valor da multa Decision of an authority
- Acordo de Leniência Minerva – Anexo III: Demonstrativo do valor, imputação e instrução para pagamento Decision of an authority
- CGU – Acordos de leniência celebrados (Liste) Official register or notice
Checked against the official source on 3 Oct 2026 · Direct link
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28 Mar 2025 Trafigura Beheer B.V.Trafigura Beheer: leniency agreement with CGU and AGU for BRL 435.4m €69.9m
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.
In corruption cases involving several countries, double payments can be avoided through coordinated agreements with all the authorities involved.
Payments to public officials and use of intermediaries
- 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.
- Acordo de Leniência CGU/AGU – Trafigura Beheer B.V. (Processo 00190.100002/2022-21, SEI 3569333) Decision of an authority
- CGU: Acordos de leniência celebrados (Liste mit Unternehmen und Beträgen) Official register or notice
Checked against the official source on 3 Oct 2026 · Direct link
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17 Mar 2025 Qualicorp Consultoria e Corretora de Seguros S.A.Qualicorp: leniency agreement worth BRL 44.5m over payment to a public official €7.15m
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.
If management knows of or tolerates payments to officials, the fine rises; without an effective compliance programme there is also no mitigating factor.
Payment to a public official to influence official action
- 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.
- CGU/AGU – Acordo de Leniência com a Qualicorp Consultoria e Corretora de Seguros S.A. (Processo 00190.101239/2021-49) Decision of an authority
- Acordo de Leniência Qualicorp – Anexo III: Demonstrativo de cálculo e valor da multa Decision of an authority
- Acordo de Leniência Qualicorp – Anexo IV: Demonstrativo do valor, imputação e instrução para pagamento Decision of an authority
- CGU – Acordos de leniência celebrados (Liste) Official register or notice
Checked against the official source on 3 Oct 2026 · Direct link
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11 Feb 2025 Paprec GroupPNF: CJIP with Paprec Group for €17.54m after investigation into waste contracts €17.5m
Paprec Group undertook, in a CJIP (convention judiciaire d'intérêt public, French deferred prosecution agreement), to pay a public interest fine of 17,538,990 EUR, including 4,828,000 EUR already seized, and to implement a three-year compliance programme under the supervision of the Agence française anticorruption (French anti-corruption agency) (costs up to 1,000,000 EUR). The background is a judicial investigation including for bribery, favouritism in procurement, money laundering and unlawful agreements concerning contracts and concessions of French local authorities for waste treatment; validated on 11 February 2025.
Companies that depend on municipal contracts must systematically review contacts with decision-makers and tender processes for bribery and favouritism risks.
Integrity in municipal contracts and concessions
- Authority / court
- Parquet national financier (PNF); Validierung durch den Präsidenten des Tribunal judiciaire de Paris
- Area of law
- Bribery and corruption · Bribery of public officials
- Legal basis
- Art. 41-1-2 Code de procédure pénale
- Action
- Fine
- Status of proceedings
- final
- Sector
- Energy and utilities
- Published
- 11 Feb 2025
- Communiqué de presse du Procureur de la République financier, 11 février 2025 (CJIP Paprec Group) Press release of an authority
- Agence française anticorruption: Affaire Paprec group Official register or notice
Checked against the official source on 2 Oct 2026 · Direct link
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11 Feb 2025 KLUBB France SASVehicle body builder KLUBB France: CJIP over an ambulance contract in Algeria €558,024
Following a referral from the public prosecutor's office in Rennes, the PNF investigated bribery of foreign public officials in the performance of a contract for the supply of ambulances to Algeria. KLUBB France is paying a public interest fine of 558,024 EUR and is undergoing a three-year AFA compliance programme.
Medium-sized exporters are also in the spotlight: companies supplying foreign authorities need a robust anti-corruption programme under Sapin II (the French anti-corruption law).
Export contracts with state bodies
- Authority / court
- Parquet national financier (PNF); Validierung durch den Präsidenten des Tribunal judiciaire de Paris
- Area of law
- Bribery and corruption · Bribery of public officials
- Legal basis
- Art. 41-1-2 Code de procédure pénale (CJIP); Bestechung ausländischer Amtsträger
- Action
- Fine
- Status of proceedings
- final
- Sector
- Manufacturing and mechanical engineering
- Employees
- 50 to 249
- Culpability
- intentional
- Liability of senior managers
- The CJIP does not address the criminal liability of natural persons.
- Published
- 11 Feb 2025
- Communiqué de presse du procureur de la République financier – CJIP KLUBB France Press release of an authority
- CJIP KLUBB France SAS (10.02.2025) Decision of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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31 Jan 2025 Trafigura Beheer B.V.Swiss Federal Criminal Court (Bundesstrafgericht) convicts Trafigura of bribery in Angola €143.3m
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.
In Switzerland, companies are liable if their organisation fails to prevent bribery – and the compensatory claim can exceed the fine many times over.
Payments via intermediaries to employees of state-owned oil companies
- 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.
- Bundesstrafgericht: Verurteilung einer juristischen und drei natürlicher Personen wegen Bestechung fremder Amtsträger (SK.2023.49) Court press release
- TRAFIGURA BEHEER BV und drei natürliche Personen vor Bundesstrafgericht angeklagt Press release of an authority
- Bundesstrafgericht, Dispositiv SK.2023.49 vom 31.01.2025 Court decision
Checked against the official source on 28 Sep 2026 · Version 3 · Direct link