Compliance Radar

Who was sanctioned, and for what?

Fines, court rulings and incidents from Europe and North America: 718 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.

27cases from 6 jurisdictions
€653.5mTotal of monetary amounts (22 cases with an amount)
€236.1mLargest single case: Adani Enterprises Limited
€1.27mMedian per case with an amount

Click a bar to drill down one level.

When?

per quarter, by date of decision
Trend
PeriodCasesTotal
Q3 20230—
Q4 20231€200,000
Q1 20240—
Q2 20241€18.8m
Q3 20241€215,000
Q4 20242€244,999
Q1 20254€2.47m
Q2 20252€3.36m
Q3 20254€122.2m
Q4 20252€10.6m
Q1 20262€213m
Q2 20263€268.5m
Q3 20265€13.9m

27 cases

18 May 2026 Adani Enterprises LimitedAdani Enterprises pays 275 million USD over Iranian liquefied petroleum gas USABreaches of sanctions and embargoes €236.1m

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).

What organisations can take from it

Companies that source commodities below market price via intermediaries must actively check origin, vessel movements and documents – mere name screening against sanctions lists is not enough.

Relevance to training and awareness

Warning signs in commodity and shipping transactions (origin, AIS gaps, price discounts)

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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24 Aug 2026 Container Manufacturing Ltd.Small US machinery supplier exported spare parts for can presses to Russia USAExport control and dual-use goods €857,339

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).

What organisations can take from it

Even small businesses with few employees must check tariff codes against Russia restrictions and treat deliveries via third countries as a warning sign.

Relevance to training and awareness

HTS-based export restrictions on Russia, diversion via third countries

Missing or inadequate training played a role in the decision.

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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12 Aug 2026 Rice Lake Weighing Systems, Inc.Scale manufacturer Rice Lake liable for Italian subsidiary's indirect exports to Iran USABreaches of sanctions and embargoes €52,632

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.

What organisations can take from it

Implement sanctions requirements at foreign subsidiaries in an understandable way, in the local language and with training for all relevant employees – indirect supplies via traders are also prohibited.

Relevance to training and awareness

Sanctions training for foreign subsidiaries, indirect supplies via third countries

Missing or inadequate training played a role in the decision.

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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11 Aug 2026 Citibank, N.A., London BranchOFSI imposes 4.7 million GBP on Citibank London over Russia payments United KingdomBreaches of sanctions and embargoes €5.54m

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).

What organisations can take from it

During waves of designations, alert handling needs additional trained capacity – backlogs and wrong decisions in screening are themselves sanctions breaches.

Relevance to training and awareness

Handling sanctions alerts, escalation and freezing

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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11 Aug 2026 Volga-Dnepr Airlines LLCFederal Court: cargo airline Volga-Dnepr remains on Canadian sanctions list CanadaBreaches of sanctions and embargoes Order

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.

What organisations can take from it

Listed logistics partners often remain listed for years – anyone buying air freight must continuously screen carriers and parent companies against sanctions lists.

Relevance to training and awareness

Listings of transport service providers in partner screening

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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30 Jul 2026 Airbus Operations LimitedAirbus Operations pays 6.4 million GBP for export control breaches in technology transfer United KingdomExport control and dual-use goods €7.48m

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).

What organisations can take from it

Technology transfers by e-mail or data room are also exports – conditions, registers and records of general licences must be put into practice day to day.

Relevance to training and awareness

Licence conditions and record-keeping obligations in technology transfer

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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16 Jun 2026 Robert Bosch GmbHBosch pays 36 million USD for sensor supplies to Huawei USAExport control and dual-use goods €31.2m

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.

What organisations can take from it

Even products manufactured outside the US can be subject to US export controls via US technology – supplies to Entity List customers need their own review.

Relevance to training and awareness

US export law for foreign-made products (Foreign Direct Product Rule)

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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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.

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
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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26 Feb 2026 Teledyne FLIR LLCTeledyne FLIR: thermal imaging cameras incorrectly assessed and supplied to Entity List address USAExport control and dual-use goods €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.

What organisations can take from it

Actively incorporate new forms of listing, such as address-only entries, into screening; do not rely solely on the software provider.

Relevance to training and awareness

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.

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

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11 Feb 2026 Applied Materials, Inc. und Applied Materials Korea, Ltd.Applied Materials pays 252 million USD for chip equipment exports to China USAExport control and dual-use goods €212.2m

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.

What organisations can take from it

Routing through foreign subsidiaries does not remove the licence requirement; export control needs audits and clear accountability of management.

Relevance to training and awareness

Entity List screening for deliveries via subsidiaries

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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2 Dec 2025 IPI Partners, LLCPrivate equity firm IPI held oligarch's funds for four years after designation USABreaches of sanctions and embargoes €9.89m

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.

What organisations can take from it

Screen investors through to the beneficial owner and re-check them when new designations occur – nested structures do not protect against liability.

Relevance to training and awareness

Checking beneficial owners of investors and fund structures

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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1 Dec 2025 British exporter pays 620,515 GBP for unlicensed exports of military goods United KingdomExport control and dual-use 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).

What organisations can take from it

Weaknesses in internal export control become expensive even without intent – disclosing breaches early can avoid prosecution.

Relevance to training and awareness

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.

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

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10 Sep 2025 Colorcon LimitedPharmaceutical supplier Colorcon paid Moscow salaries via sanctioned banks United KingdomBreaches of sanctions and embargoes €176,590

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.

What organisations can take from it

Anyone approving payments must also screen the recipient's bank against sanctions lists – and report breaches discovered without delay.

Relevance to training and awareness

Payment approval with screening of the recipient bank, prompt reporting

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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3 Sep 2025 Fracht FWO Inc.Freight forwarder Fracht FWO chartered blocked Venezuelan airline with Mahan Air jet USABreaches of sanctions and embargoes €1.38m

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.

What organisations can take from it

Urgent customer orders never justify skipping sanctions screening of carriers and of the aircraft or vessels used.

Relevance to training and awareness

Business partner screening under time pressure, circumvention of internal approvals

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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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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2 Jul 2025 Key Holding, LLCLogistics company Key Holding: Colombian subsidiary organised 36 shipments to Cuba USABreaches of sanctions and embargoes €517,929

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.

What organisations can take from it

After an acquisition, roll out the sanctions compliance programme to the new foreign subsidiary immediately – the Cuba embargo applies to US-controlled subsidiaries worldwide.

Relevance to training and awareness

Sanctions compliance after acquisitions

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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16 Jun 2025 Unicat Catalyst Technologies, LLCCatalyst manufacturer Unicat supplied Iran and blocked Venezuelan company USABreaches of sanctions and embargoes €3.35m

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.

What organisations can take from it

When senior management itself steers embargo business, only independent controls and whistleblower channels help – voluntary self-disclosure after discovery reduces the penalty but does not prevent it.

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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11 Apr 2025 Svarog Shipping & Trading Company LimitedTanker shipping company Svarog left OFSI information request unanswered United KingdomBreaches of sanctions and embargoes €5,768

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.

What organisations can take from it

Information requests from sanctions authorities need a clear intake channel and deadline monitoring – merely missing the deadline is already an offence.

Relevance to training and awareness

Handling requests from authorities and deadlines

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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10 Feb 2025 EPPO freezes assets: Chinese stainless steel declared as Korean ItalyCustoms Order

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.

What organisations can take from it

False origin declarations for steel subject to anti-dumping duties are prosecuted across borders by the EU prosecutor – with asset freezes already at the investigation stage.

Relevance to training and awareness

Origin declarations for steel imports and liability of management

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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3 Feb 2025 Customs investigators: machinery manufacturer allegedly declared Indian steel as British GermanyCustoms Incident

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.

What organisations can take from it

For steel, the actual origin determines the customs burden – check supplier declarations from intermediaries for plausibility.

Relevance to training and awareness

Preferential and origin rules when buying steel via intermediaries

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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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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17 Jan 2025 Haas Automation, Inc.Haas Automation: CNC parts and unlock codes for blocked Russian defence companies USABreaches of sanctions and embargoes €2.47m

From December 2019 to March 2022, the Californian machine tool manufacturer indirectly supplied, via its dealer network, one CNC machine, 13 spare parts orders and seven unlock codes for machines of blocked Russian defence and energy companies. The US Treasury's Office of Foreign Assets Control (OFAC) imposed 1,044,781 USD (eight of the 21 violations egregious, no voluntary self-disclosure); at the same time, Haas paid 1.5 million USD to the US Commerce Department's Bureau of Industry and Security (BIS).

What organisations can take from it

Spare parts and software unlock codes for machines already delivered are also services relevant to sanctions – end customers behind dealers must be known.

Relevance to training and awareness

End-customer screening in dealer sales, software unlocks as a service

Authority / court
U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC); parallel U.S. Department of Commerce, Bureau of Industry and Security (BIS)
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; E.O. 13662); Export Administration Regulations
Action
Fine
Status of proceedings
final
Sector
Manufacturing and mechanical engineering
Mitigating circumstances
Substantial remedial measures and extensive cooperation
Published
17 Jan 2025

Original amount 2,544,781 USD, converted at the ECB reference rate of 17 Jan 2025.

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

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13 Dec 2024 C.H. Robinson International, Inc.C.H. Robinson: foreign subsidiaries transported Iranian and Cuban goods USABreaches of sanctions and embargoes €244,999

From November 2018 to February 2022, five foreign subsidiaries of the logistics group acquired through takeovers brokered or transported a total of 82 shipments involving Iranian or Cuban goods or an Iranian airline. The main cause was that their booking systems had not yet been integrated into the group's screening processes; the US Treasury's Office of Foreign Assets Control (OFAC) considered the case non-egregious and voluntarily self-disclosed.

What organisations can take from it

Connect acquired freight forwarders to central screening quickly; until then, interim controls on origin and carrier are needed.

Relevance to training and awareness

Integrating acquired companies into sanctions screening

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; Cuban Assets Control Regulations
Action
Fine
Status of proceedings
final
Sector
Transport, logistics and shipping
Employees
10,000 or more
Culpability
negligent
Repeat case
no
Mitigating circumstances
Voluntary self-disclosure, no prior violations, swift remediation
Published
13 Dec 2024

Original amount 257,690 USD, converted at the ECB reference rate of 13 Dec 2024.

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

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7 Nov 2024 Seven years' imprisonment: machine tools for sniper rifles to Russian arms manufacturer GermanyBreaches of sanctions and embargoes Custodial sentence

In 2015, despite the Russia embargo, the 56-year-old managing director of a Baden-Württemberg machine tool company and a Swiss holding company supplied six machine tools with accessories to a Russian arms manufacturer for the series production of sniper rifles, and concealed the recipient and intended use. The 2nd Criminal Division of the Stuttgart Higher Regional Court (Oberlandesgericht Stuttgart, Ref. 2 St 3 BJs 48/22) imposed an aggregate sentence of seven years' imprisonment; around 3 million EUR was confiscated from the holding company and 2.1 million EUR from the defendant (of which 674,000 EUR jointly and severally). Not final.

What organisations can take from it

Embargo breaches with a defence connection are prosecuted as state security cases – even years later and with confiscation from foreign holding companies.

Authority / court
Oberlandesgericht Stuttgart, 2. Strafsenat (Az. 2 St 3 BJs 48/22)
Area of law
Sanctions and export control · Breaches of sanctions and embargoes
Legal basis
§§ 17, 18 Außenwirtschaftsgesetz i. V. m. Beschluss 2014/512/GASP und Verordnung (EU) Nr. 833/2014
Action
Custodial sentence
Status of proceedings
unknown
Sector
Manufacturing and mechanical engineering
Culpability
intentional
Liability of senior managers
Managing director personally sentenced to seven years' imprisonment.
Published
7 Nov 2024

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

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23 Sep 2024 Amsterdam company pays settlement: dividend paid out to oligarch's company NetherlandsBreaches of sanctions and embargoes €215,000

At the end of 2021, a company based in Amsterdam paid out a dividend of around 18 million EUR to a Russian shareholder behind which there was a sanctioned person, repaid a loan to a listed Russian company in 2019 and did not freeze shares and voting rights; in addition, a gatekeeper was misinformed. In a settlement (transactie) with the Dutch Public Prosecution Service (Openbaar Ministerie), the company paid 195,000 EUR and the managing director, as de facto manager, 20,000 EUR.

What organisations can take from it

Dividends, loan repayments and voting rights vis-à-vis shareholders with a sanctioned owner in the background are also frozen – gatekeepers must know the full structure.

Relevance to training and awareness

Freezing shares of listed shareholders, beneficial owners

Authority / court
Openbaar Ministerie (Staatsanwaltschaft der Niederlande)
Area of law
Sanctions and export control · Breaches of sanctions and embargoes
Legal basis
Sanctiewet 1977 i. V. m. EU-Finanzsanktionen gegen Russland (seit 2014)
Action
Fine
Status of proceedings
final
Sector
Other
Liability of senior managers
The managing director paid 20,000 EUR as de facto manager.
Published
23 Sep 2024

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

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19 Apr 2024 SCG Plastics Co., Ltd.SCG Plastics pays 20 million USD for concealed sales of Iranian polyethylene USABreaches of sanctions and embargoes €18.8m

In 2017–2018, the Thai plastics company had US banks process 467 payments totalling 291 million USD for HDPE plastic produced in an Iranian joint venture with the state-owned National Petrochemical Company. Shipping and documentation practices concealed the Iranian origin. The penalty was imposed by the US Treasury's Office of Foreign Assets Control (OFAC).

What organisations can take from it

Invoicing in US dollars brings US sanctions law into the business – holdings in embargoed countries require strict separation of payment flows.

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)
Action
Fine
Status of proceedings
final
Sector
Chemicals and pharmaceuticals
Culpability
intentional
Published
19 Apr 2024

Original amount 20,000,000 USD, converted at the ECB reference rate of 19 Apr 2024.

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

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31 Oct 2023 Woerd-Tech BVWoerd-Tech BV: 200,000 EUR penalty for microchips to Russian defence customers NetherlandsExport control and dual-use goods €200,000

The company of a Russian-Dutch national from Gorssel sold microchips, semiconductors and other electronics to a Russian purchasing organisation with an FSB licence and to customers from the defence industry, and after the tightening of sanctions in 2022 routed shipments ostensibly via the Maldives and other countries. Following charges brought by the Dutch Public Prosecution Service (Openbaar Ministerie, OM), the Rotterdam District Court (Rechtbank Rotterdam) imposed a fine of 200,000 EUR on the BV (final after the appeals were withdrawn) and 18 months' imprisonment on the managing director (appeal proceedings pending).

What organisations can take from it

Banks report suspicious Russia payments to the FIU – sham routes via third countries are uncovered in this way and hit both companies and management.

Authority / court
Rechtbank Rotterdam; Anklage Openbaar Ministerie
Area of law
Sanctions and export control · Export control and dual-use goods
Legal basis
Sanctiewet 1977 (EU-Russland-Sanktionen); Urkundenfälschung (valsheid in geschrifte)
Action
Fine
Status of proceedings
final
Sector
Retail and e-commerce
Culpability
intentional
Liability of senior managers
Managing director sentenced at first instance to 18 months' imprisonment; in the appeal proceedings, the OM demanded three years and a professional ban.
Published
14 Apr 2025

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

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