Who was sanctioned, and for what?

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).

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

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.

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.

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

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.

Authority / court

U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC)

Area of law

Sanctions and export control · Breaches of sanctions and embargoes

Legal basis

Iranian Transactions and Sanctions Regulations, § 560.215 (Auslandstöchter von US-Personen)

Action

Fine

Status of proceedings

final

Sector

Manufacturing and mechanical engineering

Culpability

negligent

Repeat case

no

Mitigating circumstances

Voluntary self-disclosure, immediate internal investigation, low significance for turnover, no prior violations, cooperation; subsequent training of the subsidiary's employees and screening of traders

Published

12 Aug 2026

Original amount 60,764 USD, converted at the ECB reference rate of 12 Aug 2026.

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

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).

Authority / court

HM Treasury, Office of Financial Sanctions Implementation (OFSI)

Area of law

Sanctions and export control · Breaches of sanctions and embargoes

Legal basis

Russia (Sanctions) (EU Exit) Regulations 2019; Global Anti-Corruption Sanctions Regulations 2021; s. 146 Policing and Crime Act 2017

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Employees

10,000 or more

Mitigating circumstances

Predominantly voluntary disclosure and cooperation (20% reduction); exceptional burden caused by the 2022 sanctions packages taken into account

Published

2 Sep 2026

Original amount 4,732,830.58 GBP, converted at the ECB reference rate of 11 Aug 2026.

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

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.

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

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.

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.

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

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.

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.

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

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).

Authority / court

HM Revenue & Customs (HMRC) / Export Control Joint Unit

Area of law

Sanctions and export control · Export control and dual-use goods

Legal basis

Export Control Order 2008, Art. 29(2) und 29(3) (Auflagen und Register bei OGELs) sowie Auflage einer SIEL; Straftaten nach Art. 38(1)(a) und (b); Compound Settlement durch HMRC

Action

Fine

Status of proceedings

final

Sector

Manufacturing and mechanical engineering

Employees

10,000 or more

Mitigating circumstances

Voluntary disclosure, full cooperation, remedial measures

Published

30 Jul 2026

Original amount 6,409,388 GBP, converted at the ECB reference rate of 30 Jul 2026.

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

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.

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.

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

The company paid HMRC a compound settlement of £569,157.07 for alleged breaches of the Russia sanctions. According to HMRC, while withdrawing from Russia in 2022/2023 it allegedly made sanctioned industrial goods available on two occasions to a person connected with Russia or for use in Russia, and provided related technical assistance. According to HMRC, this is the first time it has publicly named the company behind such a settlement.

Authority / court

HM Revenue & Customs (HMRC)

Area of law

Sanctions and export control · Breaches of sanctions and embargoes

Legal basis

Reg. 46Y(2)(c) und Reg. 46Z(1)(b) Russia (Sanctions) (EU Exit) Regulations 2019

Action

Fine

Status of proceedings

final

Sector

Energy and utilities

Mitigating circumstances

Voluntary disclosure and full cooperation with HMRC.

Published

29 Jun 2026

Original amount 569,157.07 GBP, converted at the ECB reference rate of 29 Jun 2026.

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

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.

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

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.

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

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. According to the annual accounts filed with the UK companies register for financial year 2024, the company had around 150 employees.

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

Employees

50 to 249

Mitigating circumstances

Voluntary disclosure (31 October 2022) and full cooperation; settlement under the new settlement procedure

Published

17 Jun 2026

Original amount 1,000,920.59 GBP, converted at the ECB reference rate of 26 May 2026.

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

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.

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.

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

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).

Authority / court

U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC)

Area of law

Sanctions and export control · Breaches of sanctions and embargoes

Legal basis

Iranian Transactions and Sanctions Regulations (31 C.F.R. part 560); IEEPA

Action

Fine

Status of proceedings

final

Sector

Energy and utilities

Mitigating circumstances

Remedial measures after discovery and cooperation with OFAC

Published

18 May 2026

Original amount 275,000,000 USD, converted at the ECB reference rate of 18 May 2026.

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

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.

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.

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

On 30 April 2026 OFSI imposed a monetary penalty of GBP 165,000 on the London branch of Deutsche Bank AG by way of settlement. According to OFSI's findings, in June and July 2022 the branch processed two payments totalling GBP 635,618.75 for a customer to a Russian app developer owned by a designated entity. According to OFSI, its screening provider's list did not contain ownership information on the designated entity, so the beneficiary was not identified. The bank had voluntarily disclosed the payments on 20 September 2022. After a notice of intent of 12 September 2025, which OFSI upheld on 2 December 2025, the bank requested a ministerial review on 23 January 2026; the proceedings ended in settlement. The publication does not state the amount originally proposed. Source: Office of Financial Sanctions Implementation (OFSI), HM Treasury, "Imposition of Monetary Penalty – Deutsche Bank AG London Branch (“DBLB”)", 19 May 2026, https://www.gov.uk/government/publications/imposition-of-monetary-penalty-deutsche-bank-ag-london-branch-dblb. Contains public sector information licensed under the Open Government Licence v3.0 (https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/).

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; Geldbuße nach s. 146 Policing and Crime Act 2017

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Published

19 May 2026

Original amount 165,000 GBP, converted at the ECB reference rate of 30 Apr 2026.

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

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.

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.

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

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.

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.

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

On 19 March 2026 OFSI imposed a monetary penalty of GBP 390,000 on Ireland-based Apple Distribution International Limited by way of settlement. According to OFSI's findings, the company, which pays out revenues to software developers on an app marketplace, instructed two payments totalling GBP 635,618.75 in June and July 2022 from a UK bank account to a Russian app developer owned by a designated entity, and did not cancel the instructions. OFSI identified reliance on developers' self-declarations and on third-party data, among other things, as causes. The company had voluntarily disclosed the payments on 4 October 2022. The settlement followed a notice of intent of 11 November 2025 and was reached under the settlement process introduced in February 2026; OFSI made no findings against the parent company. Source: Office of Financial Sanctions Implementation (OFSI), HM Treasury, "Imposition of monetary penalty: Apple Distribution International Limited", 30 March 2026, https://www.gov.uk/government/publications/imposition-of-monetary-penalty-apple-distribution-international-limited. Contains public sector information licensed under the Open Government Licence v3.0 (https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/).

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; Geldbuße nach s. 146 Policing and Crime Act 2017 (Settlement)

Action

Fine

Status of proceedings

final

Sector

Telecoms, IT and software

Published

30 Mar 2026

Original amount 390,000 GBP, converted at the ECB reference rate of 19 Mar 2026.

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

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.

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

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.

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

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.

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.

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

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.

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

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.

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

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.

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.

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

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.

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.

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

OFAC has imposed a penalty of USD 7,139,305 on New York property management company Gracetown, Inc. by way of a Penalty Notice. According to OFAC's findings, between April 2018 and May 2020 Gracetown received 24 payments on behalf of an affiliated company owned by a sanctioned Russian oligarch, although OFAC had previously given it explicit notice of the prohibition. Gracetown also failed to report the blocked property to OFAC for more than 45 months. OFAC regarded the violations as wilful or at least reckless, egregious and not voluntarily self-disclosed; the base penalty equalled the statutory maximum of USD 8,906,358. OFAC's publication does not state whether Gracetown has paid the penalty or challenged it in court. Source: U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC), enforcement release "OFAC Imposes $7,139,305 Penalty on Gracetown, Inc. for Violating Ukraine-/Russia-Related Sanctions and Reporting Obligations", 4 December 2025, https://ofac.treasury.gov/media/934796/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. § 589.201; Reporting, Procedures and Penalties Regulations, 31 C.F.R. § 501.603 (Sperrmeldung); Penalty Notice nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A

Action

Fine

Status of proceedings

unknown

Sector

Construction and real estate

Published

4 Dec 2025

Original amount 7,139,305 USD, converted at the ECB reference rate of 4 Dec 2025.

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

In 2017/2018, the Chicago fund manager specialising in data centres took in capital from a Russian oligarch 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.

Authority / court

U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC)

Area of law

Sanctions and export control · Breaches of sanctions and embargoes

Legal basis

Ukraine-/Russia-Related Sanctions Regulations (31 C.F.R. part 589); IEEPA

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Mitigating circumstances

No prior violations in five years; cooperation improved significantly only after initially insufficient engagement (including waiver of attorney-client privilege), hence only limited credit

Published

2 Dec 2025

Original amount 11,485,352 USD, converted at the ECB reference rate of 2 Dec 2025.

Checked against the official source on 27 Sep 2026 · Version 2 · Direct link

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).

Authority / court

HM Revenue & Customs (HMRC) / Export Control Joint Unit

Area of law

Sanctions and export control · Export control and dual-use goods

Legal basis

Export Control Order 2008

Action

Fine

Status of proceedings

final

Sector

Defence and security

Culpability

negligent

Mitigating circumstances

Voluntary disclosure (prerequisite for the compound settlement)

Published

1 Dec 2025

Original amount 620,515.04 GBP, converted at the ECB reference rate of 1 Dec 2025.

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

The audio electronics group (brands include Harman Kardon and JBL) allegedly imported heat sinks made of Chinese extruded aluminium from 2011 to 2023 without paying the anti-dumping and countervailing duties owed; after the failure was brought to its attention, the company allegedly did not disclose it. The settlement of 11,809,628 USD resolves a whistleblower lawsuit (share around 2.3 million USD).

Authority / court

U.S. Attorney’s Office Eastern District of Michigan (Department of Justice) mit CBP und Department of Commerce

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

Manufacturing and mechanical engineering

Published

26 Nov 2025

Original amount 11,809,628 USD, converted at the ECB reference rate of 26 Nov 2025.

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

US fintech Exodus Movement, Inc. is paying USD 3,103,360 under a settlement with OFAC for 254 apparent violations of the Iran sanctions. According to OFAC's findings, Exodus provided customer support to users in Iran and in some cases helped them access third-party crypto exchanges through its own wallet software. According to OFAC, on twelve occasions staff, despite being aware of the sanctions, advised users to hide their location via VPN in order to circumvent those exchanges' controls; OFAC treated these instances as egregious. The apparent violations were not voluntarily disclosed; the base penalty was USD 4,774,400. Extensive remediation and cooperation were taken into account. Exodus satisfies USD 630,000 of the settlement amount by investing in additional sanctions controls; USD 2,473,360 is payable to the Treasury. OFAC signed the settlement agreement on 19 November 2025 and published it on 16 December 2025. According to the settlement agreement, the settlement does not constitute an admission by Exodus of the apparent violations. Source: U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC), enforcement release "Exodus Movement, Inc. Settles with OFAC for $3,103,360 for Apparent Violations of Iran-related Sanctions Regulations", 16 December 2025, https://ofac.treasury.gov/media/934831/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 (254 mutmaßliche Verstöße), in 12 Fällen zusätzlich § 560.203 (Umgehung); 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

16 Dec 2025

Original amount 3,103,360 USD, converted at the ECB reference rate of 19 Nov 2025.

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

On 10 November 2025 OFSI imposed a monetary penalty of GBP 160,000 on Bank of Scotland PLC; without the 50 per cent discount for voluntary disclosure it would have been GBP 320,000, according to OFSI. According to OFSI's findings, between 8 and 24 February 2023 the bank processed 24 payments totalling GBP 77,383.39 through the account of a person designated under Russia sanctions, including credits of GBP 76,000. According to OFSI, screening failed to pick up a variant of the name, and a human error occurred during a PEP review on 20 February 2023. The notice of intent of 28 August 2025 had proposed GBP 175,000. The bank did not request a ministerial review. Source: Office of Financial Sanctions Implementation (OFSI), HM Treasury, "Imposition of monetary penalty: Bank of Scotland PLC", 26 January 2026, https://www.gov.uk/government/publications/imposition-of-monetary-penalty-bank-of-scotland-plc. Contains public sector information licensed under the Open Government Licence v3.0 (https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/).

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. 11, 12; Geldbuße nach s. 146 Policing and Crime Act 2017

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Published

26 Jan 2026

Original amount 160,000 GBP, converted at the ECB reference rate of 10 Nov 2025.

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

Crypto exchange ShapeShift AG, incorporated in Switzerland and operated from Denver, Colorado, is paying USD 750,000 under a settlement with OFAC for apparent violations of multiple sanctions programmes. According to OFAC's findings, between December 2016 and October 2018 ShapeShift exchanged digital assets worth USD 12,570,956 with users in Cuba, Iran, Sudan and Syria in 17,183 instances, although IP addresses revealed their location. The company introduced a sanctions compliance programme only after receiving an OFAC subpoena. OFAC treated the apparent violations as non-egregious and not voluntarily self-disclosed; the base penalty was USD 39,515,000. The low settlement amount reflects the fact that ShapeShift has ceased operations and has limited assets. Source: U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC), enforcement release "ShapeShift AG Settles with OFAC for $750,000 Related to Apparent Violations of Multiple Sanctions Programs", 22 September 2025, https://ofac.treasury.gov/media/934641/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

Cuban Assets Control Regulations, 31 C.F.R. § 515.201(b) (39); Iranian Transactions and Sanctions Regulations, 31 C.F.R. § 560.204 (16.839); Sudanese Sanctions Regulations, 31 C.F.R. § 538.205 (33); Syrian Sanctions Regulations, 31 C.F.R. § 542.207 (272); 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

22 Sep 2025

Original amount 750,000 USD, converted at the ECB reference rate of 22 Sep 2025.

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

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. According to the annual accounts filed with the UK companies register for financial year 2025, the company had around 280 employees.

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

Employees

250 to 999

Mitigating circumstances

Disclosure and full cooperation, but delayed

Published

30 Sep 2025

Original amount 152,750 GBP, converted at the ECB reference rate of 10 Sep 2025.

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

On 8 September 2025 OFSI published a report on sanctions breaches by Vanquis Bank Limited but did not impose a monetary penalty. According to OFSI's findings, the account of a person designated under counter-terrorism sanctions remained fully usable for eight days after the designation; during that time GBP 200 was withdrawn in cash and a purchase of GBP 8.99 was made. OFSI had given the bank advance notice the day before the designation. According to OFSI, the staff responsible had been redeployed to remediation work, so the internal one-day deadline for the freeze was missed. The bank reported the breach itself, but only 13 days after the designation. Type of measure: Breach published by OFSI instead of a monetary penalty (disclosure under s. 149(3) PACA 2017). The publication does not mention any pending review. Source: Office of Financial Sanctions Implementation (OFSI), HM Treasury, "Disclosure notice: 08 September 2025", 8 September 2025, https://www.gov.uk/government/publications/disclosure-notice-08-september-2025. Contains public sector information licensed under the Open Government Licence v3.0 (https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/).

Authority / court

HM Treasury, Office of Financial Sanctions Implementation (OFSI)

Area of law

Sanctions and export control · Breaches of sanctions and embargoes

Legal basis

regulations 11 and 12 of the Counter-Terrorism (Sanctions) (EU Exit) Regulations 2019; Veröffentlichung nach section 149(3) Policing and Crime Act 2017

Action

Other

Status of proceedings

unknown

Sector

Financial services and insurance

Published

8 Sep 2025

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

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.

Authority / court

U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC)

Area of law

Sanctions and export control · Breaches of sanctions and embargoes

Legal basis

Venezuela-, Iran-, Proliferations- und Terrorismus-Sanktionsprogramme (OFAC); IEEPA

Action

Fine

Status of proceedings

final

Sector

Transport, logistics and shipping

Culpability

negligent

Repeat case

no

Mitigating circumstances

No prior violations in five years, immediate remediation, substantial cooperation

Liability of senior managers

According to OFAC, the violation was driven primarily by two vice presidents who bypassed internal screening processes.

Published

3 Sep 2025

Original amount 1,610,775 USD, converted at the ECB reference rate of 3 Sep 2025.

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

The Dallas-based supplier of countertops allegedly declared Chinese quartz surface products between 2018 and 2023 as goods subject to lower duties, such as marble or crystallised glass, and evaded anti-dumping and countervailing duties, including by using third parties as importers of record. The settlement of 12.4 million USD (a joint payment with a further settling party) resolves a whistleblower lawsuit.

Authority / court

U.S. Department of Justice, Civil Division, und U.S. Attorney’s Office Northern District of Texas

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

Construction and real estate

Liability of senior managers

Measures against individuals are not reported here.

Published

19 Aug 2025

Original amount 12,400,000 USD, converted at the ECB reference rate of 19 Aug 2025.

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

In 2024 the freight forwarder Ayzo Pte Ltd misused the Unique Entity Numbers of two other companies in applications for export permits for cigarette shipments to Australia that were described as other goods in the shipping documents, and failed to retain the bills of lading. Ayzo had relied solely on information from an unknown client in India without verifying it with the named importers and exporters. After the company pleaded guilty to ten charges under the Customs Act for incorrect UEN declarations and three charges for failure to retain trade documents, the State Courts imposed a fine of SGD 36,000 on 30 July 2025.

Authority / court

Singapore Customs; Verurteilung durch die State Courts

Area of law

Sanctions and export control · Customs

Legal basis

Customs Act (unrichtige Angabe der Unique Entity Number); drei weitere Anklagepunkte wegen fehlender Aufbewahrung von Handelsdokumenten (Vorschrift in der Mitteilung nicht genannt)

Action

Fine

Status of proceedings

unknown

Sector

Transport, logistics and shipping

Published

19 Aug 2025

Original amount 36,000 SGD, converted at the ECB reference rate of 30 Jul 2025.

Checked against the official source on 4 Oct 2026 · Direct link

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.

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