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.

5cases from 1 jurisdiction
€365.2mTotal of monetary amounts
€31.2mMedian 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 20230—
Q1 20240—
Q2 20240—
Q3 20240—
Q4 20240—
Q1 20250—
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Q3 20251€120.1m
Q4 20250—
Q1 20262€213m
Q2 20261€31.2m
Q3 20261€857,339

5 cases

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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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 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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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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