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.
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Where?
by regionAll jurisdictions
What for?
by action- Fine €373.6m 100 % · 8 cases
Who?
by sectorAll sectors
When?
per quarter, by date of decision| Period | Cases | Total |
|---|---|---|
| Q3 2023 | 0 | — |
| Q4 2023 | 1 | €200,000 |
| Q1 2024 | 0 | — |
| Q2 2024 | 0 | — |
| Q3 2024 | 0 | — |
| Q4 2024 | 0 | — |
| Q1 2025 | 0 | — |
| Q2 2025 | 0 | — |
| Q3 2025 | 1 | €120.1m |
| Q4 2025 | 1 | €706,898 |
| Q1 2026 | 2 | €213m |
| Q2 2026 | 1 | €31.2m |
| Q3 2026 | 2 | €8.33m |
8 cases
11 Feb 2026 Applied Materials, Inc. und Applied Materials Korea, Ltd.Applied Materials pays 252 million USD for chip equipment exports to China €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.
Routing through foreign subsidiaries does not remove the licence requirement; export control needs audits and clear accountability of management.
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.
- BIS: Applied Materials to Pay $252 Million Penalty for Illegally Exporting Semiconductor Manufacturing Equipment (12.02.2026) Press release of an authority
- BIS Order Relating to Applied Materials, Inc. and Applied Materials Korea (11.02.2026) Decision of an authority
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 €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).
Even small businesses with few employees must check tariff codes against Russia restrictions and treat deliveries via third countries as a warning sign.
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.
- BIS Reaches Administrative Enforcement Settlement with Container Manufacturing Ltd. (24.08.2026) Press release of an authority
- BIS Order Relating to Container Manufacturing Ltd. Decision of an authority
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 €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).
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.
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.
- Notice to exporters 2026/17: company named in compound settlement for breaches of export control Press release of an authority
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 €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.
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.
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.
- BIS: Robert Bosch GmbH (Bosch) to Pay $36 Million Penalty for BIS Violations Pertaining to Shipments to Huawei (17.06.2026) Press release of an authority
- BIS Order Relating to Robert Bosch GmbH (16.06.2026) Decision of an authority
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 €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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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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28 Jul 2025 Cadence Design Systems Inc.Cadence pleads guilty: chip design software for Chinese military university €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.
Include cover names and known aliases of listed customers in screening; sales and compliance must escalate indications of military end users.
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.
- DOJ: Cadence Design Systems Agrees to Plead Guilty and Pay Over $140 Million for Unlawfully Exporting to Military University in China (28.07.2025) Press release of an authority
- BIS: Cadence Design Systems to Pay $95 Million Penalty to BIS for Unauthorized Exports to Chinese Entities (28.07.2025) Press release of an authority
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 €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).
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
- OM: OM eist in hoger beroep 3 jaar celstraf en een beroepsverbod voor omzeilen EU-sancties Rusland (14.04.2025) Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link