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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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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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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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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After the acquisition of a Colombian logistics company in December 2021, the latter organised 36 freight shipments to Cuba worth around 3.06 million USD up to July 2023. Neither the US parent nor the subsidiary had a sanctions compliance programme for foreign companies; the US Treasury's Office of Foreign Assets Control (OFAC) assessed the case as non-egregious and 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

Cuban Assets Control Regulations (31 C.F.R. part 515)

Action

Fine

Status of proceedings

final

Sector

Transport, logistics and shipping

Culpability

negligent

Repeat case

no

Mitigating circumstances

Voluntary self-disclosure, no prior violations, remedial measures after discovery

Published

2 Jul 2025

Original amount 608,825 USD, converted at the ECB reference rate of 2 Jul 2025.

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

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In 2016–2021, the Texas supplier of catalysts for refineries and steelworks supplied products and advice to customers in Iran via its former CEO, employees and agents, and sold goods to a blocked Venezuelan company. The US Treasury's Office of Foreign Assets Control (OFAC) considered it an egregious but voluntarily self-disclosed case; there were parallel settlements with the DOJ and BIS, which were taken into account in determining the amount.

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; Venezuela Sanctions Regulations; IEEPA

Action

Fine

Status of proceedings

final

Sector

Chemicals and pharmaceuticals

Culpability

intentional

Mitigating circumstances

Voluntary self-disclosure, cooperation and remedial measures after discovery

Liability of senior managers

According to OFAC, the violations were carried out by the former CEO and co-founder as well as former employees.

Published

16 Jun 2025

Original amount 3,882,797 USD, converted at the ECB reference rate of 16 Jun 2025.

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

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In the context of investigations into dealings with a Sovcomflot subsidiary, the fuel shipping company registered in the UK and operating from Cyprus did not respond in time to a formal information request from HM Treasury's Office of Financial Sanctions Implementation (OFSI); a response only came after contact via its auditors. No sanctions breach as such was found, but the information offence was.

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. 72, 74(1)(a)

Action

Fine

Status of proceedings

final

Sector

Transport, logistics and shipping

Culpability

negligent

Mitigating circumstances

Minor, indirect harm; the response was provided subsequently

Published

8 May 2025

Original amount 5,000 GBP, converted at the ECB reference rate of 11 Apr 2025.

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

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In 110 imports via a customs agency in Ferrara, two companies are alleged to have declared stainless steel coils from China as being of South Korean origin, thereby evading almost 2.4 million EUR in additional duty under the 2019 EU anti-dumping regulation; 60 further imports by one of the companies using the same method involve around 950,000 EUR. At the request of the Bologna office of the European Public Prosecutor's Office (EPPO), assets totalling more than 3.3 million EUR were frozen; searches took place in Ferrara, Varese, Milan and La Spezia.

Authority / court

Europäische Staatsanwaltschaft (EPPO), Büro Bologna

Area of law

Sanctions and export control · Customs

Legal basis

EU-Antidumpingverordnung von 2019 (Edelstahlcoils aus China); Hinterziehung von Einfuhrzöllen

Action

Order

Status of proceedings

unknown

Sector

Steel and metals

Liability of senior managers

Those responsible at the companies are alleged to have certified the South Korean origin.

Published

10 Feb 2025

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

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From March 2021, a machinery manufacturer from the Rhein-Neckar district is alleged to have declared steel products worth more than 2.9 million EUR as being of British origin in more than 100 customs clearances, although the steel came from India and was only imported via the UK; correctly, 25% higher import duties would have been payable. In December 2024, the Stuttgart customs investigation office (Zollfahndungsamt Stuttgart), acting on behalf of the European Public Prosecutor's Office (EPPO), searched business premises in Germany and at the British seller; the damage is estimated at several hundred thousand euros.

Authority / court

Zollfahndungsamt Stuttgart im Auftrag der Europäischen Staatsanwaltschaft (EPPO)

Area of law

Sanctions and export control · Customs

Legal basis

Verdacht der Steuerhinterziehung (Einfuhrabgaben nach EU-Zollrecht, falsche Ursprungsangaben)

Action

Incident without known action

Status of proceedings

unknown

Sector

Steel and metals

Published

3 Feb 2025

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

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