Compliance Radar
Who was sanctioned, and for what?
Fines, court rulings and incidents from Europe and North America: 756 cases from 32 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.
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Where?
by regionAll jurisdictions
What for?
by action- Other €130.8m 89 % · 10 cases
- Fine €16.1m 11 % · 1 case
Who?
by sectorAll sectors
When?
per quarter, by date of decision| Period | Cases | Total |
|---|---|---|
| Q3 2023 | 0 | — |
| Q4 2023 | 0 | — |
| Q1 2024 | 0 | — |
| Q2 2024 | 1 | €11.1m |
| Q3 2024 | 2 | €35.7m |
| Q4 2024 | 0 | — |
| Q1 2025 | 0 | — |
| Q2 2025 | 1 | €16.1m |
| Q3 2025 | 0 | — |
| Q4 2025 | 1 | €5.79m |
| Q1 2026 | 1 | €843,519 |
| Q2 2026 | 2 | €33m |
| Q3 2026 | 3 | €44.4m |
11 cases
30 Jul 2026 Access DX Laboratory, LLCAccess DX Laboratory: 36.4 million USD – kickbacks for unnecessary genetic tests €31.7m
The Houston laboratory, its former CEO Michael Stewart and the businessman Harold Shatz allegedly paid kickbacks and billed Medicare and Medicaid for medically unnecessary genetic tests. The three settlements add up to 36.4 million USD; the laboratory is subject to a Corporate Integrity Agreement.
Commission models for intermediaries who bring in orders or patients are a classic gateway for bribery.
Remuneration of intermediaries and referrers
- 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
- Former CEO pays under a separate settlement.
Original amount 36,400,000 USD, converted at the ECB reference rate of 30 Jul 2026.
- HHS-OIG Enforcement Actions: Texas Laboratory, Former CEO, and Florida Businessman Pay a Total of $36.4M … (30.07.2026) Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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20 Jul 2026 NeoGenomics Laboratories Inc.NeoGenomics: 9.8 million USD after self-disclosure – discounted consulting for referring physicians €8.59m
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.
Free or discounted services are also benefits – like cash payments, they belong in the anti-corruption review.
Services with monetary value provided to customers below market value
- 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.
- HHS-OIG Enforcement Actions: Florida Laboratory Agrees to Pay $9.8M … Self-Disclosure of Compensation Arrangements (20.07.2026) Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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20 Jul 2026 EyePoint Pharmaceuticals, Inc.EyePoint: 4.66 million USD – kickbacks to surgery centres for purchasing an eye medicine €4.08m
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.
Discounts, payments or services to institutions that make purchasing decisions require a documented consideration at market value.
Granting benefits to customers and purchasing decision-makers
- 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.
- HHS-OIG Enforcement Actions: EyePoint Pharmaceuticals to Pay $4.6 Million to Resolve False Claims Act Allegations (20.07.2026) Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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17 Jun 2026 Advanced Pathology Solutions PLLC und APS MSO LLCAdvanced Pathology Solutions: 30 million USD for kickbacks and unnecessary laboratory tests €25.9m
The Arkansas pathology laboratory, its management company and the owners Kevin Hannah, Donell Burkett and Daniel Hunter Pledger allegedly granted unlawful kickbacks and ordered medically unnecessary tests. Together they paid 30 million USD; the laboratory entered into a Corporate Integrity Agreement.
Where services are sold through referrals, all benefits to referrers belong in a central approval and review procedure.
Benefits to clients in healthcare
- 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
- The owners contribute personally as parties to the settlement.
Original amount 30,000,000 USD, converted at the ECB reference rate of 17 Jun 2026.
- HHS-OIG Enforcement Actions: Arkansas Pathology Laboratory and Its Owners Pay $30M … (17.06.2026) Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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1 May 2026 Modern Nuclear Inc.Modern Nuclear: 8.33 million USD – excessive supervision fees paid to referring cardiologists €7.12m
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.
Remuneration of business partners who refer work must correspond to the market value of the service – any overpayment acts as a bribe.
Checking fee agreements with referrers for market conformity
- 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.
- HHS-OIG Enforcement Actions: Mobile PET Scan Provider to Pay $8.33 Million … Unlawful Kickbacks to Medical Practices (01.05.2026) Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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5 Mar 2026 Allin IP DX LLCAllin IP DX: 980,000 USD after self-disclosure over paid referral marketers €843,519
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.
Early self-disclosure limits the damage – but this requires the compliance function to actually get to see problematic sales contracts.
Success-based remuneration of sales partners
- 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.
- HHS-OIG Enforcement Actions: Sarasota Lab Agrees to Pay $980,000 to Resolve False Claims Act Violations (05.03.2026) Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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22 Dec 2025 New York-Presbyterian Hudson Valley HospitalNYP Hudson Valley Hospital: 6.8 million USD for payments to referring practice €5.79m
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.
Cooperation agreements between hospitals and office-based practices must properly document services and remuneration – otherwise payments are treated as referral bonuses.
Payments to referrers in hospitals
- 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.
- HHS-OIG Enforcement Actions: U.S. Attorney Announces $6.8 Million Settlement With New York-Presbyterian Hudson Valley Hospital … (22.12.2025) Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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19 Jun 2025 Exclusive Networks Corporate SASIT distributor Exclusive Networks: CJIP of 16 million EUR following a whistleblower report €16.1m
In 2021, a whistleblower reported payments by subsidiaries in Indonesia, Malaysia, Vietnam, Thailand and India to contractual partners; the investigation concerned private-sector bribery and bribery of foreign public officials. The CJIP provides for a public interest fine of 16,074,511 EUR (including 1 million EUR already seized) and a three-year AFA compliance programme.
A functioning whistleblowing system uncovers foreign risks – companies should investigate reports themselves before the authorities do.
Payments to sales partners in Asia, whistleblowing systems
- Authority / court
- Parquet national financier (PNF); Validierung durch das Tribunal judiciaire de Paris
- Area of law
- Bribery and corruption · Commercial bribery
- Legal basis
- Art. 41-1-2 Code de procédure pénale (CJIP); Bestechung im privaten Sektor und ausländischer Amtsträger
- Action
- Fine
- Status of proceedings
- final
- Sector
- Telecoms, IT and software
- Employees
- 1,000 to 9,999
- Culpability
- intentional
- Liability of senior managers
- The CJIP does not address the criminal liability of natural persons.
- Published
- 19 Jun 2025
- Communiqué de presse du procureur de la République financier – CJIP Exclusive Networks Corporate Press release of an authority
- CJIP société Exclusive Networks Corporate (16.06.2025) Decision of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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18 Jul 2024 DaVita Inc.DaVita: 34.5 million USD – kickbacks for referrals to dialysis centres and pharmacy €31.6m
The dialysis group allegedly paid kickbacks to promote referrals to its former pharmacy subsidiary DaVita Rx and granted benefits to nephrologists and vascular surgeons to induce them to send patients to DaVita dialysis centres. DaVita paid 34,487,390 USD.
Intra-group routing of customers to subsidiaries must not be bought with benefits for third parties.
Benefits for referrers
- 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.
- HHS-OIG Enforcement Actions: DaVita To Pay Over $34M To Resolve Allegations Of Illegal Kickbacks (18.07.2024) Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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1 Jul 2024 Guardian Health Care Inc., Gem City Home Care LLC, Care Connection of Cincinnati LLC und Evolution Health LLCEvolution Health home care providers: 4.5 million USD – kickbacks to senior living facilities and physicians €4.18m
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.
Cooperation with facilities that refer customers requires written contracts with remuneration at market rates and regular review.
Benefits for cooperation partners who refer customers
- 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.
- HHS-OIG Enforcement Actions: Home Health Providers To Pay $4.5M … Kickbacks To Assisted Living Facilities And Doctors (01.07.2024) Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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29 May 2024 Innovasis Inc.Innovasis: 12 million USD – kickbacks to spine surgeons €11.1m
The Utah manufacturer of spinal implants and two executives – founder and president Brent Felix and former CFO Garth Felix – allegedly paid surgeons kickbacks to induce them to use Innovasis products. Together they paid 12 million USD; HHS-OIG placed the company under heightened scrutiny.
Consultancy agreements, royalty payments or fees to users who decide on the use of products require proof of need and a fair market value review.
Payments to users of medical devices
- 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
- Founder/president and former CFO pay personally as parties to the settlement.
Original amount 12,000,000 USD, converted at the ECB reference rate of 29 May 2024.
- HHS-OIG Enforcement Actions: Medical Device Manufacturer Innovasis Inc. and Two Top Executives Agree to Pay $12M … (29.05.2024) Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link