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.
Click a bar to drill down one level.
Where?
by regionAll jurisdictions
What for?
by action- Fine 14 cases 82 % · €279.9m
- Order 2 cases 12 % ·
- Custodial sentence 1 case 6 % ·
Who?
by sectorAll sectors
- Transport, logistics and shipping 5 cases 29 % · €2.15m
- Chemicals and pharmaceuticals 3 cases 18 % · €22.3m
- Manufacturing and mechanical engineering 3 cases 18 % · €2.52m
- Financial services and insurance 2 cases 12 % · €15.4m
- Telecoms, IT and software 2 cases 12 % · €1.16m
- Energy and utilities 1 case 6 % · €236.1m
- Other 1 case 6 % · €215,000
When?
per quarter, by date of decision| Period | Cases | Total |
|---|---|---|
| Q3 2023 | 0 | — |
| Q4 2023 | 0 | — |
| Q1 2024 | 0 | — |
| Q2 2024 | 1 | €18.8m |
| Q3 2024 | 1 | €215,000 |
| Q4 2024 | 2 | €244,999 |
| Q1 2025 | 2 | €2.47m |
| Q2 2025 | 2 | €3.36m |
| Q3 2025 | 3 | €2.08m |
| Q4 2025 | 1 | €9.89m |
| Q1 2026 | 0 | — |
| Q2 2026 | 2 | €237.3m |
| Q3 2026 | 3 | €5.59m |
17 cases
12 Aug 2026 Rice Lake Weighing Systems, Inc.Scale manufacturer Rice Lake liable for Italian subsidiary's indirect exports to Iran €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.
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.
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.
- 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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11 Aug 2026 Citibank, N.A., London BranchOFSI imposes 4.7 million GBP on Citibank London over Russia payments €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).
During waves of designations, alert handling needs additional trained capacity – backlogs and wrong decisions in screening are themselves sanctions breaches.
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.
- OFSI: Imposition of Monetary Penalty – Citibank, N.A., London Branch Decision of an authority
- OFSI – Enforcement of financial sanctions (Sammlung) Enforcement database of an authority
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 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.
Listed logistics partners often remain listed for years – anyone buying air freight must continuously screen carriers and parent companies against sanctions lists.
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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26 May 2026 Sabre Global Technologies LimitedSabre subsidiary accepted payments from designated Ural Airlines €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.
If an existing customer is designated, escalate this immediately; looking for alternative payment routes after the bank has frozen funds is itself a breach.
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.
- OFSI: Imposition of Monetary Penalty – Sabre Global Technologies Limited Decision of an authority
- OFSI – Enforcement of financial sanctions (Sammlung) Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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18 May 2026 Adani Enterprises LimitedAdani Enterprises pays 275 million USD over Iranian liquefied petroleum gas €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).
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.
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.
- 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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2 Dec 2025 IPI Partners, LLCPrivate equity firm IPI held oligarch's funds for four years after designation €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.
Screen investors through to the beneficial owner and re-check them when new designations occur – nested structures do not protect against liability.
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.
- OFAC Enforcement Release: IPI Partners, LLC Settles with OFAC for $11,485,352 (02.12.2025) Decision of an authority
- OFAC – 2025 Enforcement Information Enforcement database of an authority
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 €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.
Anyone approving payments must also screen the recipient's bank against sanctions lists – and report breaches discovered without delay.
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.
- OFSI: Imposition of Monetary Penalty – Colorcon Limited Decision of an authority
- OFSI – Enforcement of financial sanctions (Sammlung) Enforcement database of an authority
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 €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.
Urgent customer orders never justify skipping sanctions screening of carriers and of the aircraft or vessels used.
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.
- OFAC Enforcement Release: Fracht FWO Inc. Settles with OFAC for $1,610,775 (03.09.2025) Decision of an authority
- OFAC – 2025 Enforcement Information Enforcement database of an authority
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 €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.
After an acquisition, roll out the sanctions compliance programme to the new foreign subsidiary immediately – the Cuba embargo applies to US-controlled subsidiaries worldwide.
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.
- OFAC Enforcement Release: Key Holding, LLC Settles with OFAC for $608,825 (02.07.2025) Decision of an authority
- OFAC – 2025 Enforcement Information Enforcement database of an authority
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 €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.
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.
- OFAC Enforcement Release: Unicat Catalyst Technologies, LLC Settles with OFAC for $3,882,797 (16.06.2025) Decision of an authority
- OFAC – 2025 Enforcement Information Enforcement database of an authority
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 €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.
Information requests from sanctions authorities need a clear intake channel and deadline monitoring – merely missing the deadline is already an offence.
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.
- OFSI: Imposition of Monetary Penalty – Svarog Shipping & Trading Company Limited Decision of an authority
- OFSI – Enforcement of financial sanctions (Sammlung) Enforcement database of an authority
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 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.
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 €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).
Spare parts and software unlock codes for machines already delivered are also services relevant to sanctions – end customers behind dealers must be known.
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.
- OFAC Enforcement Release: Haas Automation, Inc. Settles with OFAC for $1,044,781 (17.01.2025) Decision of an authority
- OFAC – 2025 Enforcement Information Enforcement database of an authority
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 €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.
Connect acquired freight forwarders to central screening quickly; until then, interim controls on origin and carrier are needed.
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.
- OFAC Enforcement Release: C.H. Robinson International Inc. Settles with OFAC for $257,690 (13.12.2024) Decision of an authority
- OFAC – 2024 Enforcement Information Enforcement database of an authority
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 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.
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
- OLG Stuttgart, 2. Strafsenat: Angeklagter wegen vier Verstößen gegen das AWG i. V. m. dem Russland-Embargo zu 7 Jahren verurteilt (07.11.2024) Court press release
- Generalbundesanwalt: Anklage wegen mutmaßlicher Verstöße gegen das Außenwirtschaftsgesetz erhoben (13.11.2023) Press release of an authority
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 €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.
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.
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
- OM: Transacties na verdenking overtredingen Sanctiewet (23.09.2024) Press release of an authority
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 €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).
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.
- OFAC Enforcement Release: SCG Plastics Co., Ltd. Settles with OFAC for $20,000,000 (19.04.2024) Decision of an authority
- OFAC – 2024 Enforcement Information Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link