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.

7cases from 3 jurisdictions
€399.3mTotal of monetary amounts (6 cases with an amount)
€1.94mMedian per case with an amount

Click a bar to drill down one level.

When?

per year, by date of decision
Trend
PeriodCasesTotal
20232€277.1m
20241€459,348
20252€120.1m
20262€1.61m

7 cases

26 May 2026 Sabre Global Technologies LimitedSabre subsidiary accepted payments from designated Ural Airlines United KingdomBreaches of sanctions and embargoes €1.16m

The provider of a travel booking system continued to provide services to Ural Airlines, designated in May 2022, requested payments of around 906,600 USD and, after the funds were frozen by the bank, looked for alternative payment routes, which HM Treasury's Office of Financial Sanctions Implementation (OFSI) regarded as circumvention. A lack of escalation during a change of roles, vacant leadership positions in legal and compliance, policies focused on US law and screening that did not flag the designation all contributed. According to the annual accounts filed with the UK companies register for financial year 2024, the company had around 150 employees.

What organisations can take from it

If an existing customer is designated, escalate this immediately; looking for alternative payment routes after the bank has frozen funds is itself a breach.

Relevance to training and awareness

Responding to new designations of existing customers, prohibition of circumvention

Authority / court
HM Treasury, Office of Financial Sanctions Implementation (OFSI)
Area of law
Sanctions and export control · Breaches of sanctions and embargoes
Legal basis
Russia (Sanctions) (EU Exit) Regulations 2019, regs. 13, 14, 19
Action
Fine
Status of proceedings
final
Sector
Telecoms, IT and software
Employees
50 to 249
Mitigating circumstances
Voluntary disclosure (31 October 2022) and full cooperation; settlement under the new settlement procedure
Published
17 Jun 2026

Original amount 1,000,920.59 GBP, converted at the ECB reference rate of 26 May 2026.

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

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19 Mar 2026 Apple Distribution International LimitedOFSI: GBP 390,000 settlement penalty for Apple Distribution International over payments to an app developer United KingdomBreaches of sanctions and embargoes €451,452

On 19 March 2026 OFSI imposed a monetary penalty of GBP 390,000 on Ireland-based Apple Distribution International Limited by way of settlement. According to OFSI's findings, the company, which pays out revenues to software developers on an app marketplace, instructed two payments totalling GBP 635,618.75 in June and July 2022 from a UK bank account to a Russian app developer owned by a designated entity, and did not cancel the instructions. OFSI identified reliance on developers' self-declarations and on third-party data, among other things, as causes. The company had voluntarily disclosed the payments on 4 October 2022. The settlement followed a notice of intent of 11 November 2025 and was reached under the settlement process introduced in February 2026; OFSI made no findings against the parent company. Source: Office of Financial Sanctions Implementation (OFSI), HM Treasury, "Imposition of monetary penalty: Apple Distribution International Limited", 30 March 2026, https://www.gov.uk/government/publications/imposition-of-monetary-penalty-apple-distribution-international-limited. Contains public sector information licensed under the Open Government Licence v3.0 (https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/).

Authority / court
HM Treasury, Office of Financial Sanctions Implementation (OFSI)
Area of law
Sanctions and export control · Breaches of sanctions and embargoes
Legal basis
Russia (Sanctions) (EU Exit) Regulations 2019, reg. 12; Geldbuße nach s. 146 Policing and Crime Act 2017 (Settlement)
Action
Fine
Status of proceedings
final
Sector
Telecoms, IT and software
Published
30 Mar 2026

Original amount 390,000 GBP, converted at the ECB reference rate of 19 Mar 2026.

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

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28 Jul 2025 Cadence Design Systems Inc.Cadence pleads guilty: chip design software for Chinese military university USAExport control and dual-use goods €120.1m

From 2015 to 2021, the San José provider of chip design software supplied hardware, software and semiconductor IP at least 59 times to the National University of Defense Technology (NUDT), a military university on the Entity List, disguised under the alias Central South CAD Center. Cadence pleaded guilty before the US Department of Justice to conspiracy to commit export control violations; criminal penalties of almost 118 million USD and civil penalties of more than 95 million USD imposed by the Bureau of Industry and Security (BIS) result, after crediting, in a net total of more than 140 million USD.

What organisations can take from it

Include cover names and known aliases of listed customers in screening; sales and compliance must escalate indications of military end users.

Relevance to training and awareness

Recognising aliases and cover names of listed customers

Authority / court
U.S. Department of Justice; Bureau of Industry and Security (BIS)
Area of law
Sanctions and export control · Export control and dual-use goods
Legal basis
Export Administration Regulations (Entity List); ECRA; Verschwörung zu Exportkontrollverstößen
Action
Fine
Status of proceedings
unknown
Sector
Telecoms, IT and software
Employees
10,000 or more
Culpability
intentional
Published
28 Jul 2025

Original amount 140,000,000 USD, converted at the ECB reference rate of 28 Jul 2025.

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

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29 Jan 2025 Mobile TeleSystems Public Joint Stock Company (MTS)Federal Court dismisses mobile operator MTS's challenge to sanctions listing CanadaBreaches of sanctions and embargoes Order

Russia's largest mobile and fixed-line operator challenged its inclusion on the Canadian Russia sanctions list directly in court. The Federal Court (2025 FC 181) upheld the striking out of the application, sought by the Attorney General of Canada, without leave to amend, because MTS should first have used the delisting procedure before the Minister provided for in the Regulations.

What organisations can take from it

The route against a sanctions listing is first the administrative delisting procedure; business partners must observe the listing until then.

Authority / court
Federal Court (2025 FC 181); Attorney General of Canada
Area of law
Sanctions and export control · Breaches of sanctions and embargoes
Legal basis
Special Economic Measures Act; Regulations Amending the Special Economic Measures (Russia) Regulations, SOR/2023-163, s. 8
Action
Order
Status of proceedings
unknown
Sector
Telecoms, IT and software

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

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1 Nov 2024 GlobalFoundries U.S. Inc.; GlobalFoundries U.S. 2 LLCBIS: USD 500,000 against GlobalFoundries for shipments to a listed company USAExport control and dual-use goods €459,348

As part of a settlement, the Bureau of Industry and Security imposed a civil penalty of USD 500,000 on GlobalFoundries U.S. Inc. and its subsidiary GlobalFoundries U.S. 2 LLC. Between February 2021 and October 2022 the company sent semiconductor wafers worth around USD 17.1 million in 74 shipments without authorisation to SJ Semiconductor, a company on the Entity List; owing to a data entry error, the service provider designated by the customer had not been screened in the screening system. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

Service providers designated by customers, such as test and assembly contractors, must also be screened against sanctions and Entity Lists.

Relevance to training and awareness

Sanctions list screening of all parties to a transaction

Authority / court
U.S. Department of Commerce, Bureau of Industry and Security (BIS)
Area of law
Sanctions and export control · Export control and dual-use goods
Legal basis
15 C.F.R. § 764.2(a) (Export Administration Regulations)
Action
Fine
Status of proceedings
final
Sector
Telecoms, IT and software
Mitigating circumstances
According to BIS, voluntary self-disclosure, cooperation and remedial measures led to a significant reduction of the penalty.
Published
1 Nov 2024

Original amount 500,000 USD, converted at the ECB reference rate of 1 Nov 2024.

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

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19 Apr 2023 a US hard disk drive manufacturer and its entity in SingaporeBIS: USD 300 million against US hard drive maker for shipments to Chinese group USAExport control and dual-use goodsanonymised €274.4m

The Bureau of Industry and Security imposed a civil penalty of USD 300 million on a US hard disk drive manufacturer and its international headquarters in Singapore, payable in 20 quarterly instalments of USD 15 million. Between August 2020 and September 2021, the manufacturer supplied around 7.4 million foreign-produced hard disk drives worth about USD 1.1 billion on 429 occasions without authorisation to entities of a Chinese telecommunications group on the Entity List, although these were subject to the foreign direct product rule. The order also provides for three audits of the export compliance programme and a denial order suspended for five years.

What organisations can take from it

The foreign direct product rule also covers products manufactured abroad – supply chains must be checked for US technology used in production.

Relevance to training and awareness

Foreign direct product rule and supplies to companies on the Entity List

Authority / court
U.S. Department of Commerce, Bureau of Industry and Security (BIS)
Area of law
Sanctions and export control · Export control and dual-use goods
Legal basis
15 C.F.R. § 764.2(a) (Export Administration Regulations); Export Control Reform Act of 2018 (50 U.S.C. §§ 4801–4852)
Action
Fine
Status of proceedings
final
Sector
Telecoms, IT and software
Published
19 Apr 2023

Original amount 300,000,000 USD, converted at the ECB reference rate of 19 Apr 2023.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 19 Apr 2025 · Direct link

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6 Apr 2023 a US software groupOFAC: USD 2.98 million settlement with US software group over software and service exports to blocked persons and sanctioned jurisdictions USABreaches of sanctions and embargoesanonymised €2.73m

A software group based in Washington State is paying USD 2,980,265.86 under a settlement with OFAC on behalf of itself and its Irish and Russian subsidiaries for 1,339 apparent violations of the Cuba, Iran, Syria and Ukraine-/Russia-related sanctions programmes. According to OFAC's findings, software and services worth around USD 12.1 million were supplied to blocked Russian entities and persons and to users in Crimea and other sanctioned jurisdictions because screening processes did not reliably detect prohibited parties and name variations. OFAC treated the apparent violations as non-egregious and voluntarily self-disclosed and credited extensive remedial measures; the base penalty was USD 5,960,531.72. At the same time the company settled with the Bureau of Industry and Security for USD 624,013. Summarised in our own words.

Authority / court
U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC)
Area of law
Sanctions and export control · Breaches of sanctions and embargoes
Legal basis
Cuban Assets Control Regulations, 31 C.F.R. § 515.201(b)(2) (54); Iranian Transactions and Sanctions Regulations, 31 C.F.R. §§ 560.204, 560.206(a)(2) (30); Syrian Sanctions Regulations, 31 C.F.R. § 542.207 (3); Ukraine-/Russia-Related Sanctions Regulations, 31 C.F.R. § 589.207 (1.252); Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A
Action
Fine
Status of proceedings
final
Sector
Telecoms, IT and software
Published
6 Apr 2023

Original amount 2,980,265.86 USD, converted at the ECB reference rate of 6 Apr 2023.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 6 Apr 2025 · Direct link

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