Who was sanctioned, and for what?

From November 2023 to June 2025, the Indian conglomerate bought allegedly Omani and Iraqi liquefied petroleum gas (LPG) via a trader in Dubai which in fact originated from Iran; 32 payments totalling around 192 million USD were routed through US banks. The US Treasury's Office of Foreign Assets Control (OFAC) assessed the violations as egregious and not voluntarily self-disclosed; Adani had recklessly ignored numerous warning signs (AIS manipulation by the tankers, implausible loading ports, conspicuous price discounts, irregularities in the certificates of origin).

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

Iranian Transactions and Sanctions Regulations (31 C.F.R. part 560); IEEPA

Action

Fine

Status of proceedings

final

Sector

Energy and utilities

Mitigating circumstances

Remedial measures after discovery and cooperation with OFAC

Published

18 May 2026

Original amount 275,000,000 USD, converted at the ECB reference rate of 18 May 2026.

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

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Between March 2023 and March 2025, the Ohio manufacturer of presses for beverage can ends (nine employees) supplied, in ten instances, spare parts for aluminium forming tools worth around 264,700 USD – partly via the UAE and Turkey – without a licence to a Russian customer whose group also supplies defence precursors. In two instances, the company acted with knowledge of the violation; it admitted the allegations, which were brought by the US Commerce Department's Bureau of Industry and Security (BIS).

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, § 746.8(a)(5) (HTS-Codes Supplement No. 4 to Part 746), §§ 764.2(a), 764.2(e)

Action

Fine

Status of proceedings

final

Sector

Manufacturing and mechanical engineering

Employees

Under 50

Mitigating circumstances

Full cooperation; compliance programme subsequently expanded with screening, an approval process and additional export control training

Published

24 Aug 2026

Original amount 1,000,000 USD, converted at the ECB reference rate of 24 Aug 2026.

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

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In eight instances in 2019–2021, the Italian subsidiary Dini Argeo supplied weighing equipment worth around 121,500 USD to a trader in the UAE, although it knew that the goods would be passed on to a former direct Iranian customer. The parent company had passed on the Iran ban only by an English-language e-mail without explanation; the US Treasury's Office of Foreign Assets Control (OFAC) considered it a non-egregious, voluntarily self-disclosed case.

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

Iranian Transactions and Sanctions Regulations, § 560.215 (Auslandstöchter von US-Personen)

Action

Fine

Status of proceedings

final

Sector

Manufacturing and mechanical engineering

Culpability

negligent

Repeat case

no

Mitigating circumstances

Voluntary self-disclosure, immediate internal investigation, low significance for turnover, no prior violations, cooperation; subsequent training of the subsidiary's employees and screening of traders

Published

12 Aug 2026

Original amount 60,764 USD, converted at the ECB reference rate of 12 Aug 2026.

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

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Mainly between February and November 2022, the London branch processed 970 payments totalling around 19.7 million GBP that breached Russia and anti-corruption sanctions. The causes were overloaded alert handling after the wave of designations, delayed escalation and human error; the bank voluntarily disclosed most of the breaches and received a 20% reduction from HM Treasury's Office of Financial Sanctions Implementation (OFSI).

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; Global Anti-Corruption Sanctions Regulations 2021; s. 146 Policing and Crime Act 2017

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Employees

10,000 or more

Mitigating circumstances

Predominantly voluntary disclosure and cooperation (20% reduction); exceptional burden caused by the 2022 sanctions packages taken into account

Published

2 Sep 2026

Original amount 4,732,830.58 GBP, converted at the ECB reference rate of 11 Aug 2026.

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

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The Russian cargo airline had been added to the list of the Special Economic Measures (Russia) Regulations in April 2023; the Minister of Foreign Affairs rejected the application for delisting. The Federal Court (2026 FC 1048) dismissed the application for judicial review: the Minister had not exercised her broad discretion unreasonably, and there was no procedural error.

Authority / court

Federal Court (2026 FC 1048); Minister of Foreign Affairs

Area of law

Sanctions and export control · Breaches of sanctions and embargoes

Legal basis

Special Economic Measures Act; Special Economic Measures (Russia) Regulations, SOR/2014-58, ss. 2(a), 8

Action

Order

Status of proceedings

unknown

Sector

Transport, logistics and shipping

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

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Over an extended period before November 2022, Airbus Operations Ltd breached the Export Control Order 2008: transfers of controlled technology under three open general export licences (OGEL) were not correctly documented, required registers were missing, and one individual licence was not complied with. The case came to light through voluntary disclosure and was concluded by HM Revenue & Customs (HMRC) by way of a compound settlement (date of publication).

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, Art. 29(2) und 29(3) (Auflagen und Register bei OGELs) sowie Auflage einer SIEL; Straftaten nach Art. 38(1)(a) und (b); Compound Settlement durch HMRC

Action

Fine

Status of proceedings

final

Sector

Manufacturing and mechanical engineering

Employees

10,000 or more

Mitigating circumstances

Voluntary disclosure, full cooperation, remedial measures

Published

30 Jul 2026

Original amount 6,409,388 GBP, converted at the ECB reference rate of 30 Jul 2026.

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

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Between September 2020 and September 2024, Bosch exported MEMS sensors and vehicle software worth around 72.4 million USD from outside the US without a licence to Huawei and affiliated companies on the Entity List (Foreign Direct Product Rule). Bosch voluntarily disclosed the violations; around 3.6 million USD of the penalty imposed by the US Commerce Department's Bureau of Industry and Security (BIS) is credited against a disgorgement agreed with the DOJ.

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 (Foreign Direct Product Rule, Entity List)

Action

Fine

Status of proceedings

final

Sector

Automotive

Employees

10,000 or more

Mitigating circumstances

Voluntary self-disclosure and cooperation

Published

17 Jun 2026

Original amount 36,184,680 USD, converted at the ECB reference rate of 16 Jun 2026.

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

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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.

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

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 25 Sep 2026 · Direct link

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A German import company declared aluminium foil for hairdressers made in China as goods originating in Myanmar in order to evade anti-dumping duties; a company set up specifically for this purpose in Myanmar carried out only minimal processing, which did not change the origin. Around 610,000 EUR was evaded, plus around 140,000 EUR from seven direct sales to unsuspecting German customers. Following charges brought by the European Public Prosecutor's Office (EPPO) in Cologne, the Krefeld District Court sentenced the Chinese national responsible to one year and eight months suspended and a fine of 100,000 EUR; more than 321,000 EUR was confiscated, and the proceedings against a second accused were discontinued subject to a monetary condition.

Authority / court

Gericht in Krefeld (Krefeld District Court); Anklage: Europäische Staatsanwaltschaft (EPPO) Köln; Ermittlungen Zollfahndungsamt Essen

Area of law

Sanctions and export control · Customs

Legal basis

Hinterziehung von EU-Antidumpingzöllen (Einfuhrabgaben) auf Aluminiumfolie aus China; Ursprungsregeln des EU-Zollrechts

Action

Custodial sentence

Status of proceedings

unknown

Sector

Steel and metals

Culpability

intentional

Published

31 Mar 2026

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

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A car dealer from the Bavarian Lower Main region specialising in armoured and luxury vehicles brought 111 vehicles worth almost 20 million EUR to Russia, and around 400 further vehicles were planned. The white-collar crime chamber of the Würzburg Regional Court (Landgericht Würzburg) sentenced the owner to six years' imprisonment and the former authorised signatory (Prokuristin) to two years suspended, and ordered the confiscation of around 20 million EUR; the judgment is not final.

Authority / court

Landgericht Würzburg (Wirtschaftsstrafkammer); Ermittlungen Zollfahndungsamt Essen und Staatsanwaltschaft Würzburg

Area of law

Sanctions and export control · Breaches of sanctions and embargoes

Legal basis

Außenwirtschaftsgesetz i. V. m. Russland-Embargoverordnung (EU) Nr. 833/2014 (gewerbsmäßig)

Action

Custodial sentence

Status of proceedings

unknown

Sector

Automotive

Culpability

intentional

Liability of senior managers

Owner (Andreas M.) six years' imprisonment; former authorised signatory (Inna W.) two years suspended.

Published

2 Mar 2026

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

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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.

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.

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

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In 2021 and 2022, Applied Materials and its Korean subsidiary exported ion implanters for semiconductor manufacturing worth around 126 million USD via Korea without a licence to a Chinese company placed on the Entity List in 2020. The penalty imposed by the US Commerce Department's Bureau of Industry and Security (BIS) corresponds to twice the transaction value and thus the statutory maximum; the compliance staff and executives responsible are no longer with the company.

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 (Entity List)

Action

Fine

Status of proceedings

final

Sector

Manufacturing and mechanical engineering

Employees

10,000 or more

Liability of senior managers

According to BIS, the responsible compliance staff and senior executives from sales and production are no longer employed.

Published

12 Feb 2026

Original amount 252,500,300 USD, converted at the ECB reference rate of 11 Feb 2026.

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

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A company director from Wakefield attempted to export eight thermal imaging rifle scopes classified as military goods (ML1d) to Hong Kong without a licence, declaring them as cheap cameras; Border Force stopped consignments in 2022 and 2023, and a search, following investigations by HM Revenue & Customs, revealed ten further exports. Leeds Crown Court sentenced him to two years and one month's imprisonment.

Authority / court

Leeds Crown Court; Ermittlungen HM Revenue & Customs

Area of law

Sanctions and export control · Export control and dual-use goods

Legal basis

Customs and Excise Management Act 1979, ss. 68, 167; UK Military List ML1d; Waffenembargo China/Hongkong

Action

Custodial sentence

Status of proceedings

unknown

Sector

Defence and security

Culpability

intentional

Liability of senior managers

The director Steven Gates was personally sentenced to 2 years and 1 month's imprisonment.

Published

19 Feb 2026

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

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In 2017/2018, the Chicago fund manager specialising in data centres took in capital from the Russian oligarch Suleiman Kerimov via nested structures and continued to manage this investment for four years after his designation in April 2018. The US Treasury's Office of Foreign Assets Control (OFAC) assessed the case as non-egregious and not voluntarily self-disclosed.

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

Ukraine-/Russia-Related Sanctions Regulations (31 C.F.R. part 589); IEEPA

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Mitigating circumstances

No prior violations in five years; cooperation improved significantly only after initially insufficient engagement (including waiver of attorney-client privilege), hence only limited credit

Published

2 Dec 2025

Original amount 11,485,352 USD, converted at the ECB reference rate of 2 Dec 2025.

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

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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).

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.

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

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A 55-year-old former managing director from the Tübingen area is alleged to have supplied five machine tools worth around 1.7 million EUR to Russia via various third countries between October 2023 and December 2024. The Stuttgart Local Court (Amtsgericht Stuttgart) issued an arrest warrant and an asset freeze of around 1.5 million EUR; premises searched included a freight forwarder in Duisburg. The investigations by the Stuttgart public prosecutor's office and customs investigation office are ongoing (date = press release).

Authority / court

Amtsgericht Stuttgart (Haftbefehl, Vermögensarrest); Staatsanwaltschaft Stuttgart; Zollfahndungsamt Stuttgart

Area of law

Sanctions and export control · Breaches of sanctions and embargoes

Legal basis

Außenwirtschaftsgesetz i. V. m. Verordnung (EU) Nr. 833/2014

Action

Order

Status of proceedings

unknown

Sector

Manufacturing and mechanical engineering

Liability of senior managers

Former managing director in pre-trial detention.

Published

19 Nov 2025

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

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In 2022, the Moscow office of the British subsidiary made payments – mainly salaries – to accounts at Alfa-Bank, Promsvyazbank, Sberbank and VTB; after deduction of payments covered by a general licence, around 128,300 GBP remained in breach. The approval process in the UK checked only the amount and the recipient, not the bank; because of a four-month delay in reporting, HM Treasury's Office of Financial Sanctions Implementation (OFSI) granted only a 35% instead of a 50% reduction.

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

Action

Fine

Status of proceedings

final

Sector

Chemicals and pharmaceuticals

Mitigating circumstances

Disclosure and full cooperation, but delayed

Published

30 Sep 2025

Original amount 152,750 GBP, converted at the ECB reference rate of 10 Sep 2025.

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

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In May 2022, bypassing internal compliance procedures, the Houston freight forwarder engaged a blocked Venezuelan state-owned airline for a shipment from Mexico to Argentina; the aircraft used, which was also blocked, was operated by Iran's Mahan Air. The US Treasury's Office of Foreign Assets Control (OFAC) classified the case as egregious and not voluntarily self-disclosed, partly because two vice presidents bypassed the screening under time pressure.

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

Venezuela-, Iran-, Proliferations- und Terrorismus-Sanktionsprogramme (OFAC); IEEPA

Action

Fine

Status of proceedings

final

Sector

Transport, logistics and shipping

Culpability

negligent

Repeat case

no

Mitigating circumstances

No prior violations in five years, immediate remediation, substantial cooperation

Liability of senior managers

According to OFAC, the violation was driven primarily by two vice presidents who bypassed internal screening processes.

Published

3 Sep 2025

Original amount 1,610,775 USD, converted at the ECB reference rate of 3 Sep 2025.

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

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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.

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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The person responsible for an independent car dealership sold 71 luxury vehicles with a value of goods of around 5 million EUR to Russia, feigning lawful exports to third countries. Following investigations by the Frankfurt am Main public prosecutor's office and the Essen customs investigation office, the Marburg Regional Court (Landgericht Marburg) imposed five years' imprisonment and ordered the confiscation of around 5 million EUR; the judgment is not final.

Authority / court

Landgericht Marburg; Ermittlungen Staatsanwaltschaft Frankfurt am Main und Zollfahndungsamt Essen

Area of law

Sanctions and export control · Breaches of sanctions and embargoes

Legal basis

Außenwirtschaftsgesetz i. V. m. Verordnung (EU) Nr. 833/2014 (Luxusgüterverbot)

Action

Custodial sentence

Status of proceedings

unknown

Sector

Automotive

Culpability

intentional

Liability of senior managers

The person responsible for the car dealership was personally sentenced to five years' imprisonment.

Published

11 Jul 2025

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

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