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.
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per year, by date of decision| Period | Cases | Total |
|---|---|---|
| 2024 | 2 | €227.6m |
| 2025 | 2 | €4.45m |
| 2026 | 4 | €62.9m |
8 cases
4 Aug 2026 BAE Systems, Inc.DDTC: USD 36 million against BAE Systems for ITAR violations, including a China link €31.3m
The DDTC settled with BAE Systems, Inc. for a civil penalty of USD 36 million. The allegations concerned unauthorised exports and retransfers of defence articles to several countries, in one case to the People's Republic of China, the unauthorised furnishing of defence services and breaches of authorisation provisos. USD 18 million is suspended for approved compliance measures and USD 18 million is payable in three instalments; the agreement requires, among other things, an external compliance audit. The authority allegedly made the findings set out here; this account is not based on a final judgment.
Retransfers by recipients must be controlled contractually and organisationally just as strictly as one's own exports.
ITAR compliance: retransfers, defence services and authorisation provisos
- Authority / court
- U.S. Department of State, Directorate of Defense Trade Controls (DDTC)
- Area of law
- Sanctions and export control · Export control and dual-use goods
- Legal basis
- Arms Export Control Act § 38 (22 U.S.C. § 2778); ITAR, 22 C.F.R. Parts 120–130, insbesondere Part 127 und § 128.11
- Action
- Fine
- Status of proceedings
- final
- Sector
- Defence and security
- Mitigating circumstances
- The company reported the matters in voluntary disclosures and in response to a disclosure directed by the DDTC, and cooperated with the review.
Original amount 36,000,000 USD, converted at the ECB reference rate of 4 Aug 2026.
- U.S. Department of State, Order, In the Matter of BAE Systems, Inc. Decision of an authority
- U.S. Department of State, Consent Agreement, BAE Systems, Inc. Decision of an authority
- DDTC, Penalties & Oversight Agreements Enforcement database of an authority
Checked against the official source on 3 Oct 2026 · Direct link
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17 Apr 2026 General Electric CompanyDDTC: USD 36 million against General Electric for technical data exports to China €30.5m
The DDTC settled with General Electric Company for a civil penalty of USD 36 million for ITAR violations: unauthorised exports of technical data to the People's Republic of China, breaches of authorisation provisos, unauthorised exports of defence articles and failure to report material changes to its ITAR registration. USD 18 million is suspended for approved compliance measures and USD 18 million is payable in three instalments. The authority allegedly made the findings set out here; this account is not based on a final judgment.
Changes to one's own ITAR registration must also be reported and belong in the compliance calendar.
ITAR registration and control of technical data with a China link
- Authority / court
- U.S. Department of State, Directorate of Defense Trade Controls (DDTC)
- Area of law
- Sanctions and export control · Export control and dual-use goods
- Legal basis
- Arms Export Control Act § 38 (22 U.S.C. § 2778); ITAR, 22 C.F.R. Parts 120–130, insbesondere Part 127 und § 128.11
- Action
- Fine
- Status of proceedings
- final
- Sector
- Defence and security
- Employees
- 10,000 or more
- Mitigating circumstances
- The allegations are based on facts that the company itself disclosed to the DDTC.
Original amount 36,000,000 USD, converted at the ECB reference rate of 17 Apr 2026.
- U.S. Department of State, Order, In the Matter of General Electric Company Decision of an authority
- DDTC, Penalties & Oversight Agreements Enforcement database of an authority
Checked against the official source on 3 Oct 2026 · Direct link
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26 Feb 2026 Teledyne FLIR LLCTeledyne FLIR: thermal imaging cameras incorrectly assessed and supplied to Entity List address €846,453
The manufacturer of militarily relevant thermal imaging technology admitted 19 violations to the US Commerce Department's Bureau of Industry and Security (BIS): incorrect de minimis calculations for cameras that went to China via Sweden, pricing arranged with a Chinese drone manufacturer to circumvent the licence requirement, missing records and eight deliveries in 2024 to a Hong Kong address on the Entity List that the screening software did not detect.
Actively incorporate new forms of listing, such as address-only entries, into screening; do not rely solely on the software provider.
De minimis calculation, address-based Entity List entries in screening
- 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
- Export Administration Regulations, §§ 734.4 (De minimis), 744.16, 764.2(a), (b), (h), (i)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Defence and security
- Mitigating circumstances
- Voluntary self-disclosures for some of the violations
- Published
- 26 Feb 2026
Original amount 1,000,000 USD, converted at the ECB reference rate of 26 Feb 2026.
- BIS Reaches Administrative Enforcement Settlement with Teledyne FLIR LLC and its affiliates (26.02.2026) Press release of an authority
- BIS Order Relating to Teledyne FLIR LLC (26.02.2026) Decision of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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24 Feb 2026 Vizocom ICTVizocom: blueprints for military antenna sent to China and copies supplied to the US Navy €317,971
The Californian dealer had won a Navy contract for 450 VHF/UHF antennas from a US manufacturer, but in 2019 uploaded the export-controlled production specifications of the purely military antenna without a licence to the portal of a Chinese manufacturer, had the antennas produced there for 6 USD each and supplied them to the Navy with false manufacturer information for 165,109.50 USD. The Bureau of Industry and Security (BIS, the export control agency of the US Department of Commerce) imposed 374,474 USD in 20 instalments and a denial of export privileges suspended for five years.
Do not send specifications of military goods to foreign manufacturers without a licence – even uploading a drawing to a supplier portal is an export.
Technical drawings and specifications as export-controlled technology
- 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
- Export Administration Regulations, 15 C.F.R. § 764.2(a), §§ 742.4, 742.6 (ECCN 3E611)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Defence and security
- Culpability
- intentional
- Liability of senior managers
- Measures against individuals are not reported here.
- Published
- 25 Feb 2026
Original amount 374,474 USD, converted at the ECB reference rate of 24 Feb 2026.
- BIS Reaches Administrative Enforcement Settlement with Vizicom ICT Press release of an authority
- Order Relating to Vizocom ICT (24. Februar 2026) mit Settlement Agreement Decision of an authority
Checked against the official source on 28 Sep 2026 · Version 2 · Direct link
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1 Dec 2025 British exporter pays 620,515 GBP for unlicensed exports of military goods €706,898
In September 2025, an unnamed British exporter paid a compound settlement of 620,515.04 GBP to HM Revenue & Customs (HMRC) for unlicensed exports of military goods. HMRC offers such settlements only for unintentional breaches or weaknesses in internal controls and following voluntary disclosure (date = publication).
Weaknesses in internal export control become expensive even without intent – disclosing breaches early can avoid prosecution.
Classification of goods and licensing requirements for military goods
- Authority / court
- HM Revenue & Customs (HMRC) / Export Control Joint Unit
- Area of law
- Sanctions and export control · Export control and dual-use goods
- Legal basis
- Export Control Order 2008
- Action
- Fine
- Status of proceedings
- final
- Sector
- Defence and security
- Culpability
- negligent
- Mitigating circumstances
- Voluntary disclosure (prerequisite for the compound settlement)
- Published
- 1 Dec 2025
Original amount 620,515.04 GBP, converted at the ECB reference rate of 1 Dec 2025.
- NTE 2025/31: UK exporter pays compound settlement for breaches of export controls Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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9 Apr 2025 Britisches Exportunternehmen, Militärgüter (anonymisiert)UK exporter pays £3.23m for unlicensed exports of military goods €3.74m
A UK company not named by HMRC paid a compound settlement of £3,231,762.40 in February 2025 in lieu of prosecution over the alleged export of military goods without the licence required under the Export Control Order 2008. HMRC set out the facts in these terms. It was the largest of three settlements totalling close to £3.7 million that HMRC concluded between January and March 2025; no sanctions offences were involved.
Before every export, check whether the goods are military-listed and obtain the appropriate licence.
Classification of goods and licensing requirements for military goods
- Authority / court
- HM Revenue & Customs (HMRC)
- Area of law
- Sanctions and export control · Export control and dual-use goods
- Legal basis
- Export Control Order 2008; Customs and Excise Management Act 1979
- Action
- Fine
- Status of proceedings
- final
- Sector
- Defence and security
- Published
- 9 Apr 2025
Original amount 3,231,762.4 GBP, converted at the ECB reference rate of 9 Apr 2025.
Checked against the official source on 3 Oct 2026 · Direct link
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29 Aug 2024 a US defence groupDDTC: USD 200 million against US defence group for ITAR violations €180.4m
The US State Department's Directorate of Defense Trade Controls settled with a US defence group for a civil penalty of USD 200 million for violations of the Arms Export Control Act and the ITAR. The allegations concerned unauthorised exports of defence articles resulting from flawed jurisdiction and classification decisions, further unauthorised exports, including of classified defence articles, hand-carried exports by employees to countries proscribed under ITAR § 126.1, and breaches of authorisation provisos. USD 100 million is suspended provided the group spends it on approved compliance measures; USD 100 million is payable in three instalments.
Correct jurisdiction and classification decisions are the basis of every export authorisation; errors there multiply across the portfolio.
Export control for defence articles: classification, hand-carry and authorisation provisos
- Authority / court
- U.S. Department of State, Directorate of Defense Trade Controls (DDTC)
- Area of law
- Sanctions and export control · Export control and dual-use goods
- Legal basis
- Arms Export Control Act § 38 (22 U.S.C. § 2778); ITAR, 22 C.F.R. Parts 120–130, insbesondere Part 127 und § 128.11
- Action
- Fine
- Status of proceedings
- final
- Sector
- Defence and security
- Employees
- 10,000 or more
- Mitigating circumstances
- The allegations are based on facts that the group itself disclosed to the DDTC.
Original amount 200,000,000 USD, converted at the ECB reference rate of 29 Aug 2024.
Checked against the official source on 8 Oct 2026 · Company name anonymised since 29 Aug 2026 · Direct link
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28 Feb 2024 a US aerospace groupDDTC: USD 51 million against US aerospace group for unauthorised technical data transfers €47.2m
The DDTC settled with a US aerospace group for a civil penalty of USD 51 million for ITAR violations: unauthorised exports and retransfers of technical data to foreign-person employees and contractors, unauthorised exports to the People's Republic of China as a proscribed country, and breaches of authorisation provisos. USD 24 million is suspended for approved compliance measures; USD 27 million is payable in three instalments.
Access by foreign-person employees to controlled technical data is an export and requires authorisation and technical access controls.
Deemed exports: foreign-person employees' access to controlled technical data
- Authority / court
- U.S. Department of State, Directorate of Defense Trade Controls (DDTC)
- Area of law
- Sanctions and export control · Export control and dual-use goods
- Legal basis
- Arms Export Control Act § 38 (22 U.S.C. § 2778); ITAR, 22 C.F.R. Parts 120–130, insbesondere Part 127 und § 128.11
- Action
- Fine
- Status of proceedings
- final
- Sector
- Defence and security
- Employees
- 10,000 or more
- Mitigating circumstances
- The allegations are based on facts that the group itself disclosed to the DDTC.
Original amount 51,000,000 USD, converted at the ECB reference rate of 28 Feb 2024.
Checked against the official source on 8 Oct 2026 · Company name anonymised since 28 Feb 2026 · Direct link