Compliance Radar

Who was sanctioned, and for what?

Fines, court rulings and incidents from Europe, North America, Latin America, Asia-Pacific, Middle East and Africa: 2,207 cases from 44 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.

USA Sanctions and export control Clear all filters

76cases from 1 jurisdiction

€3.53bnTotal of monetary amounts (75 cases with an amount)

€884.2mLargest single case: an international crypto exchange

€3.14mMedian per case with an amount

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Federal level €3.53bn 100 % · 76 cases

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Trend
Period	Cases	Total
2022	8	€34.1m
2023	19	€1.76bn
2024	13	€272.3m
2025	17	€419.2m
2026	19	€1.05bn

76 cases

Newest first Highest amounts

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.

Sources

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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14 Aug 2026 Plexon, Inc.Plexon: brain research recording systems to listed Chinese military medical academy – 1.7 million USD suspended USAExport control and dual-use goods €1.47m

The neurotechnology company from Dallas, described by the Bureau of Industry and Security (BIS, the export control agency of the US Department of Commerce) as small, delivered neural data acquisition systems (“OmniPlex”) and accessories worth around 179,000 USD on eight occasions in 2022/23 via its Asian distributor to the Chinese Academy of Military Medical Sciences, which has been on the Entity List (the US export control list of restricted parties) since December 2021. The penalty of 1.7 million USD is suspended for five years and then waived, provided that Plexon submits an external audit of its export compliance programme on time and commits no further violations; a five-year denial of export privileges is likewise suspended, and Plexon must also provide export control training.

What organisations can take from it

Screen orders placed via distributors against the Entity List before production – research equipment can also end up with listed military institutions.

Relevance to training and awareness

Entity List screening for orders via distribution partners

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, 15 C.F.R. § 764.2(a), § 744.11
Action: Fine
Status of proceedings: final
Sector: Healthcare
Mitigating circumstances: Penalty and denial of export privileges fully suspended for five years, conditional on an external export control audit.
Published: 14 Aug 2026

Original amount 1,700,000 USD, converted at the ECB reference rate of 14 Aug 2026.

Sources

BIS Reaches Administrative Enforcement Settlement with Plexon, Inc. Press release of an authority
Order Relating to Plexon, Inc., Settlement Agreement und Proposed Charging Letter Decision of an authority

Checked against the official source on 28 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.

Sources

OFAC Enforcement Release: Rice Lake Weighing Systems Settles with OFAC for Iran-Related Apparent Violations (12.08.2026) Decision of an authority
OFAC – Civil Penalties and Enforcement Information Enforcement database of an authority

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

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5 Aug 2026 Everlight Electronics Co., Ltd. und Everlight Americas, Inc.Everlight: 5.15 million USD – Chinese LEDs declared as Taiwanese via Taiwan USACustoms €4.46m

The Taiwanese LED manufacturer and its Texas subsidiary allegedly transshipped LEDs made in China via Taiwan from 2018 to 2022 and declared them to US customs as being of Taiwanese origin in order to avoid Section 301 tariffs (US punitive tariffs on Chinese goods); in addition, Chinese and Taiwanese chips were not kept separate in production until 2025. The settlement of 5.15 million USD resolves a whistleblower lawsuit brought by a former employee, who receives around 876,000 USD.

What organisations can take from it

Where goods are routed through third countries, document their origin by manufacturing step – repackaging in Taiwan does not turn Chinese goods into Taiwanese ones.

Relevance to training and awareness

Rules of origin and origin of goods when transshipping via third countries

Authority / court: U.S. Attorney’s Office District of Maryland (Department of Justice) mit U.S. Customs and Border Protection
Area of law: Sanctions and export control · Customs
Legal basis: False Claims Act; Tariff Act of 1930 (Vergleich; Haftung nicht festgestellt)
Action: Other
Status of proceedings: final
Sector: Manufacturing and mechanical engineering
Published: 5 Aug 2026

Original amount 5,150,000 USD, converted at the ECB reference rate of 5 Aug 2026.

Sources

Taiwan LED Manufacturer Agrees to $5.15M Settlement of False Claims Act and Administrative Allegations of Evading Customs Duties Press release of an authority

Checked against the official source on 28 Sep 2026 · Direct link

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4 Aug 2026 BAE Systems, Inc.DDTC: USD 36 million against BAE Systems for ITAR violations, including a China link USAExport control and dual-use goods €31.3m

The DDTC settled with BAE Systems, Inc. for a civil penalty of USD 36 million. The allegations concerned unauthorised exports and retransfers of defence articles to several countries, in one case to the People's Republic of China, the unauthorised furnishing of defence services and breaches of authorisation provisos. USD 18 million is suspended for approved compliance measures and USD 18 million is payable in three instalments; the agreement requires, among other things, an external compliance audit. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

Retransfers by recipients must be controlled contractually and organisationally just as strictly as one's own exports.

Relevance to training and awareness

ITAR compliance: retransfers, defence services and authorisation provisos

Authority / court: U.S. Department of State, Directorate of Defense Trade Controls (DDTC)
Area of law: Sanctions and export control · Export control and dual-use goods
Legal basis: Arms Export Control Act § 38 (22 U.S.C. § 2778); ITAR, 22 C.F.R. Parts 120–130, insbesondere Part 127 und § 128.11
Action: Fine
Status of proceedings: final
Sector: Defence and security
Mitigating circumstances: The company reported the matters in voluntary disclosures and in response to a disclosure directed by the DDTC, and cooperated with the review.

Original amount 36,000,000 USD, converted at the ECB reference rate of 4 Aug 2026.

Sources

U.S. Department of State, Order, In the Matter of BAE Systems, Inc. Decision of an authority
U.S. Department of State, Consent Agreement, BAE Systems, Inc. Decision of an authority
DDTC, Penalties & Oversight Agreements Enforcement database of an authority

Checked against the official source on 3 Oct 2026 · Direct link

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15 Jul 2026 New York Packaging II LLC (Redi-Bag USA)Redi-Bag USA: 7.3 million USD – “Made in China” marking on carrier bags concealed USACustoms €6.4m

The packaging supplier allegedly imported plastic carrier bags made in China via Hong Kong and declared them as goods from Hong Kong in order to evade anti-dumping duties of up to 77.57%. According to the US Department of Justice (DOJ), the company had employees cover up “Made in China” markings, concealed the origin from its customs broker and cancelled orders that were due to be inspected; the settlement of 7.3 million USD (a joint payment with a further settling party) resolves a whistleblower lawsuit.

What organisations can take from it

Never instruct staff to conceal origin markings – doing so turns a tariff issue into deliberate customs fraud; give employees a reporting channel for such instructions.

Relevance to training and awareness

Origin declarations and handling of origin markings in goods receipt

Authority / court: U.S. Department of Justice, Civil Division, und U.S. Attorney’s Office District of New Jersey
Area of law: Sanctions and export control · Customs
Legal basis: False Claims Act, 31 U.S.C. §§ 3729 ff. (Vergleich; Haftung nicht festgestellt)
Action: Other
Status of proceedings: final
Sector: Retail and e-commerce
Liability of senior managers: Measures against individuals are not reported here.
Published: 15 Jul 2026

Original amount 7,300,000 USD, converted at the ECB reference rate of 15 Jul 2026.

Sources

U.S. Department of Justice, Pressemitteilung zum Vergleich mit Redi-Bag USA (Entscheidung 2025) Press release of an authority

Checked against the official source on 28 Sep 2026 · Version 2 · 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.

Sources

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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1 Jun 2026 FTI Consulting, Inc.OFAC: USD 1.05 million settlement with FTI Consulting over prohibited extension of credit to a Russian state-owned bank USABreaches of sanctions and embargoes €901,597

Consulting firm FTI Consulting, Inc. of Washington, D.C. is paying USD 1,050,000 under a settlement with OFAC for apparent violations of the Russia financial sector sanctions. According to OFAC's findings, between April 2019 and May 2021 FTI indirectly extended prohibited debt on six occasions to a Russian state-owned bank subject to Directive 1 under Executive Order 13662: invoices remained unpaid beyond the permitted 14 days or were paid long afterwards while FTI continued to provide services. OFAC treated the apparent violations as non-egregious and not voluntarily self-disclosed; the base penalty was USD 525,000. The settlement amount is above the base penalty; OFAC cited in particular the anticipated impact on future compliance by similarly situated firms. Source: U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC), enforcement release "FTI Consulting, Inc., a Global Business Advisory Firm, Settles with OFAC for $1,050,000 Related to Apparent Violations of Dealing in Prohibited Debt of Sanctioned Russian Bank", 1 June 2026, https://ofac.treasury.gov/media/935651/download?inline; summarised in our own words.

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. §§ 589.202, 589.213 i. V. m. Directive 1 zu E.O. 13662 (sechs mutmaßliche Verstöße); Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A
Action: Fine
Status of proceedings: final
Sector: Other
Published: 1 Jun 2026

Original amount 1,050,000 USD, converted at the ECB reference rate of 1 Jun 2026.

Sources

OFAC Enforcement Release: FTI Consulting, Inc. Settles with OFAC for $1,050,000 (01.06.2026) Decision of an authority
OFAC – Civil Penalties and Enforcement Information (2026) Enforcement database of an authority

Checked against the official source on 28 Sep 2026 · Version 3 · Direct link

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20 May 2026 Farjess Inc. und Royal Canadian Steel Inc.Canadian steel companies pay 19 million USD – steel from Asia and Europe declared as Canadian USACustoms €16.4m

Two Canadian steel companies allegedly declared flat-rolled steel from China, Indonesia, Italy, Turkey and Vietnam to US customs as being of Canadian or US origin from May 2019 to January 2025. The settlement of 19 million USD (a joint payment with a further settling party) resolves the lawsuit of a customs broker, who receives around 3.61 million USD.

What organisations can take from it

Base origin declarations in cross-border trade on mill certificates – and take note that your own customs broker is often the first to spot inconsistencies.

Relevance to training and awareness

Proof of origin in steel trading

Authority / court: U.S. Department of Justice, Civil Division, und U.S. Attorney’s Office Eastern District of Michigan
Area of law: Sanctions and export control · Customs
Legal basis: False Claims Act, 31 U.S.C. §§ 3729 ff. (Vergleich; Haftung nicht festgestellt)
Action: Other
Status of proceedings: final
Sector: Steel and metals
Liability of senior managers: Measures against individuals are not reported here.
Published: 20 May 2026

Original amount 19,000,000 USD, converted at the ECB reference rate of 20 May 2026.

Sources

U.S. Department of Justice, Pressemitteilung zum Vergleich mit Farjess Inc. und Royal Canadian Steel Inc. (Entscheidung 2025) Press release of an authority

Checked against the official source on 28 Sep 2026 · Version 2 · Direct link

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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.

Sources

OFAC Enforcement Release: Adani Enterprises Limited Settles with OFAC for $275,000,000 (18.05.2026) Decision of an authority
OFAC – Civil Penalties and Enforcement Information Enforcement database of an authority

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

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12 May 2026 Perfectus Aluminum Inc., Perfectus Aluminum Acquisitions LLC und vier verbundene LagergesellschaftenPerfectus Aluminum: 549.5 million USD – aluminium extrusions imported as sham pallets USACustoms €468.1m

From July 2011 to June 2014, the companies imported more than 2.2 million Chinese aluminium extrusions that had merely been spot-welded into “pallets”, and declared them as finished goods not subject to anti-dumping and countervailing duties – there were never any buyers for the pallets. A jury had already convicted the companies in 2021 of, among other things, conspiracy to defraud the United States; the civil settlement of 549.5 million USD resolves several whistleblower lawsuits.

What organisations can take from it

Do not use minimal processing to declare goods as finished products outside the scope of anti-dumping duties – that is duty evasion; classify goods according to what they actually are.

Relevance to training and awareness

Tariff classification and evasion of anti-dumping duties

Authority / court: U.S. Department of Justice, Civil Division, und U.S. Attorney’s Office Central District of California
Area of law: Sanctions and export control · Customs
Legal basis: False Claims Act, 31 U.S.C. §§ 3729 ff. (zivilrechtlicher Vergleich)
Action: Other
Status of proceedings: final
Sector: Steel and metals
Culpability: intentional
Published: 12 May 2026

Original amount 549,500,000 USD, converted at the ECB reference rate of 12 May 2026.

Sources

Perfectus Aluminum Inc. and Related Companies Agree to Pay $549.5M to Settle False Claims Act Allegations Relating to Evaded Customs Duties Press release of an authority

Checked against the official source on 28 Sep 2026 · Direct link

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17 Apr 2026 General Electric CompanyDDTC: USD 36 million against General Electric for technical data exports to China USAExport control and dual-use goods €30.5m

The DDTC settled with General Electric Company for a civil penalty of USD 36 million for ITAR violations: unauthorised exports of technical data to the People's Republic of China, breaches of authorisation provisos, unauthorised exports of defence articles and failure to report material changes to its ITAR registration. USD 18 million is suspended for approved compliance measures and USD 18 million is payable in three instalments. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

Changes to one's own ITAR registration must also be reported and belong in the compliance calendar.

Relevance to training and awareness

ITAR registration and control of technical data with a China link

Authority / court: U.S. Department of State, Directorate of Defense Trade Controls (DDTC)
Area of law: Sanctions and export control · Export control and dual-use goods
Legal basis: Arms Export Control Act § 38 (22 U.S.C. § 2778); ITAR, 22 C.F.R. Parts 120–130, insbesondere Part 127 und § 128.11
Action: Fine
Status of proceedings: final
Sector: Defence and security
Employees: 10,000 or more
Mitigating circumstances: The allegations are based on facts that the company itself disclosed to the DDTC.

Original amount 36,000,000 USD, converted at the ECB reference rate of 17 Apr 2026.

Sources

U.S. Department of State, Order, In the Matter of General Electric Company Decision of an authority
DDTC, Penalties & Oversight Agreements Enforcement database of an authority

Checked against the official source on 3 Oct 2026 · Direct link

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13 Apr 2026 Coastal PVA Technology, Inc.Coastal PVA: 1.7 million USD (suspended) for brushes sold to SMIC – without an export compliance programme USAExport control and dual-use goods €1.45m

The Californian manufacturer of PVA brushes for wafer cleaning sold goods worth around 400,000 USD on 18 occasions between 2021 and 2024 via two Chinese distributors to SMIC Beijing and SMIC North, both on the Entity List (the US export control list of restricted parties). The company had no formal export compliance rules; the penalty of 1.7 million USD is suspended for one year owing to limited ability to pay and will be waived if training and an internal audit are completed on time.

What organisations can take from it

Obtain a licence even for unlisted everyday goods (EAR99) when the end customer is on the Entity List – without end-customer screening, routing sales through distributors does not help.

Relevance to training and awareness

Export controls for EAR99 goods and deliveries via distributors

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, 15 C.F.R. § 764.2(a), § 744.11
Action: Fine
Status of proceedings: final
Sector: Manufacturing and mechanical engineering
Culpability: negligent
Mitigating circumstances: Payment suspended owing to demonstrated limited ability to pay; deliveries stopped after notification by BIS (Bureau of Industry and Security).
Published: 14 Apr 2026

Original amount 1,700,000 USD, converted at the ECB reference rate of 13 Apr 2026.

Sources

BIS Reaches Administrative Enforcement Settlement with Coastal PVA Technology, Inc. Press release of an authority
Order Relating to Coastal PVA Technology, Inc., Settlement Agreement und Proposed Charging Letter Decision of an authority

Checked against the official source on 28 Sep 2026 · Direct link

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17 Mar 2026 TradeStation Securities, Inc.OFAC: USD 1.11 million settlement with TradeStation over securities trading for customers in Iran, Syria and Crimea USABreaches of sanctions and embargoes €963,196

Online broker TradeStation Securities, Inc. of Florida is paying USD 1,110,661 under a settlement with OFAC for 481 apparent violations of multiple sanctions programmes. According to OFAC's findings, following several failures in compliance controls, customers in Iran, Syria and Crimea were able to execute 481 securities trades worth a total of USD 4,442,645 via the mobile app between June 2021 and June 2022. OFAC treated the apparent violations as non-egregious and voluntarily self-disclosed and credited significant remedial measures; the base penalty was USD 2,221,322. Source: U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC), enforcement release "TradeStation Securities, Inc. Settles with OFAC for $1,110,661 Related to Apparent Violations of Multiple Sanctions Regulations", 17 March 2026, https://ofac.treasury.gov/media/935351/download?inline; summarised in our own words.

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. § 560.204; Syrian Sanctions Regulations, 31 C.F.R. § 542.207; Ukraine-/Russia-Related Sanctions Regulations, 31 C.F.R. § 589.207 (481 mutmaßliche Verstöße); Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A
Action: Fine
Status of proceedings: final
Sector: Financial services and insurance
Published: 17 Mar 2026

Original amount 1,110,661 USD, converted at the ECB reference rate of 17 Mar 2026.

Sources

OFAC Enforcement Release: TradeStation Securities, Inc. Settles with OFAC for $1,110,661 (17.03.2026) Decision of an authority
OFAC – Civil Penalties and Enforcement Information (2026) Enforcement database of an authority

Checked against the official source on 28 Sep 2026 · Version 3 · 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.

Sources

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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24 Feb 2026 Vizocom ICTVizocom: blueprints for military antenna sent to China and copies supplied to the US Navy USAExport control and dual-use goods €317,971

The Californian dealer had won a Navy contract for 450 VHF/UHF antennas from a US manufacturer, but in 2019 uploaded the export-controlled production specifications of the purely military antenna without a licence to the portal of a Chinese manufacturer, had the antennas produced there for 6 USD each and supplied them to the Navy with false manufacturer information for 165,109.50 USD. The Bureau of Industry and Security (BIS, the export control agency of the US Department of Commerce) imposed 374,474 USD in 20 instalments and a denial of export privileges suspended for five years.

What organisations can take from it

Do not send specifications of military goods to foreign manufacturers without a licence – even uploading a drawing to a supplier portal is an export.

Relevance to training and awareness

Technical drawings and specifications as export-controlled technology

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, 15 C.F.R. § 764.2(a), §§ 742.4, 742.6 (ECCN 3E611)
Action: Fine
Status of proceedings: final
Sector: Defence and security
Culpability: intentional
Liability of senior managers: Measures against individuals are not reported here.
Published: 25 Feb 2026

Original amount 374,474 USD, converted at the ECB reference rate of 24 Feb 2026.

Sources

BIS Reaches Administrative Enforcement Settlement with Vizicom ICT Press release of an authority
Order Relating to Vizocom ICT (24. Februar 2026) mit Settlement Agreement Decision of an authority

Checked against the official source on 28 Sep 2026 · Version 2 · Direct link

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12 Feb 2026 IMG Academy, LLCOFAC: USD 1.72 million settlement with IMG Academy over school contracts with two sanctioned individuals USABreaches of sanctions and embargoes €1.45m

School and sports academy IMG Academy, LLC of Bradenton, Florida, is paying USD 1,720,000 under a settlement with OFAC for apparent violations of the counternarcotics sanctions. According to OFAC's findings, between 2019 and 2025 IMG Academy entered into tuition agreements for the children of two individuals on the SDN List because of their ties to a sanctioned Mexican drug cartel and processed the related payments; 89 dealings were involved in total. OFAC treated the apparent violations as non-egregious and not voluntarily self-disclosed because an investigation was already under way when the academy reported them; the settlement amount equals the base penalty. Source: U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC), enforcement release "IMG Academy, LLC Settles with OFAC for $1.7 Million Related to Apparent Violations of Counternarcotics Sanctions", 12 February 2026, https://ofac.treasury.gov/media/935006/download?inline; summarised in our own words.

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: Foreign Narcotics Kingpin Sanctions Regulations, 31 C.F.R. § 598.202 (89 mutmaßliche Verstöße); Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A
Action: Fine
Status of proceedings: final
Sector: Other
Published: 12 Feb 2026

Original amount 1,720,000 USD, converted at the ECB reference rate of 12 Feb 2026.

Sources

OFAC Enforcement Release: IMG Academy, LLC Settles with OFAC for $1.7 Million (12.02.2026) Decision of an authority
OFAC – Civil Penalties and Enforcement Information (2026) Enforcement database of an authority

Checked against the official source on 28 Sep 2026 · Version 3 · 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.

Sources

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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7 Jan 2026 Exyte Management GmbHExyte: 1.5 million USD – Chinese subsidiary arranged US goods for listed chipmaker SMIC USAExport control and dual-use goods €1.28m

The Shanghai company of the Stuttgart-based Exyte group caused around 884 US items (flowmeters, pressure transmitters, controllers) worth around 2.85 million USD to be delivered by Chinese suppliers to SMIC Beijing, which is on the Entity List (the US export control list of restricted parties), on 13 occasions in 2021/22. According to the Bureau of Industry and Security (BIS, the export control agency of the US Department of Commerce), the compliance programme did not recognise that in-country transfers within China also require a licence; Exyte voluntarily disclosed the transactions and admitted them.

What organisations can take from it

Screen end customers against the Entity List in foreign subsidiaries too, even for local purchases – US export law also covers transfers of US goods within China.

Relevance to training and awareness

Entity List screening also for domestic deliveries abroad

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, 15 C.F.R. § 764.2(b), § 744.11
Action: Fine
Status of proceedings: final
Sector: Construction and real estate
Culpability: negligent
Mitigating circumstances: Voluntary self-disclosure, own investigation with external lawyers and investment in the compliance programme.
Published: 7 Jan 2026

Original amount 1,500,000 USD, converted at the ECB reference rate of 7 Jan 2026.

Sources

BIS Imposes Administrative Penalty on Exyte Management GmbH Press release of an authority
Order Relating to Exyte Management GmbH (7. Januar 2026) mit Settlement Agreement Decision of an authority

Checked against the official source on 28 Sep 2026 · Direct link

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18 Dec 2025 Ceratizit USA LLCCeratizit USA: 54.4 million USD for misdeclared carbide products from China USACustoms €46.4m

The distributor of tungsten carbide products allegedly transshipped Chinese goods via Taiwan and declared them as Taiwanese (2020–2024), misclassified products (2015–2024) and distributed goods without country-of-origin marking. The settlement of 54.4 million USD resolves a whistleblower lawsuit; the whistleblower receives around 9.75 million USD.

What organisations can take from it

Treat origin, tariff classification and marking as three separate obligations – customs compliance that checks only one of them leaves the other risks open.

Relevance to training and awareness

Tariff classification, origin declarations and origin marking

Authority / court: U.S. Department of Justice, Civil Division, und U.S. Attorney’s Office Eastern District of Michigan
Area of law: Sanctions and export control · Customs
Legal basis: False Claims Act, 31 U.S.C. §§ 3729 ff. (Vergleich; Haftung nicht festgestellt)
Action: Other
Status of proceedings: final
Sector: Steel and metals
Published: 18 Dec 2025

Original amount 54,400,000 USD, converted at the ECB reference rate of 18 Dec 2025.

Sources

Ceratizit USA LLC Agrees to Pay $54.4M to Settle False Claims Act Allegations Relating to Evaded Customs Duties Press release of an authority

Checked against the official source on 28 Sep 2026 · Direct link

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Every case is based on a decision, press release or database of an authority or a court. Press and law-firm reports count at most as additional references.

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