Compliance Radar

Who was sanctioned, and for what?

Fines, court rulings and incidents from Europe and North America: 756 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.

21cases from 5 jurisdictions
€305.8mTotal of monetary amounts (17 cases with an amount)
€236.1mLargest single case: Adani Enterprises Limited
€1.38mMedian per case with an amount

Click a bar to drill down one level.

When?

per quarter, by date of decision
Trend
PeriodCasesTotal
Q3 20230—
Q4 20230—
Q1 20240—
Q2 20241€18.8m
Q3 20242€1.1m
Q4 20242€244,999
Q1 20252€2.47m
Q2 20252€3.36m
Q3 20254€7.08m
Q4 20252€9.89m
Q1 20261€20m
Q2 20262€237.3m
Q3 20263€5.59m

21 cases

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.

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 United KingdomBreaches of sanctions and embargoes €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).

What organisations can take from it

During waves of designations, alert handling needs additional trained capacity – backlogs and wrong decisions in screening are themselves sanctions breaches.

Relevance to training and awareness

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.

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 CanadaBreaches of sanctions and embargoes 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.

What organisations can take from it

Listed logistics partners often remain listed for years – anyone buying air freight must continuously screen carriers and parent companies against sanctions lists.

Relevance to training and awareness

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 United KingdomBreaches of sanctions and embargoes €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.

What organisations can take from it

If an existing customer is designated, escalate this immediately; looking for alternative payment routes after the bank has frozen funds is itself a breach.

Relevance to training and awareness

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.

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 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.

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

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2 Mar 2026 Autohandel aus dem Landkreis Miltenberg (Inhaber Andreas M.)Six years' imprisonment for car dealer: 111 luxury vehicles to Russia despite embargo GermanyBreaches of sanctions and embargoes €20m

A car dealer from the Bavarian Lower Main region specialising in armoured and luxury vehicles brought 111 vehicles worth almost 20 million EUR to Russia, and around 400 further vehicles were planned. The white-collar crime chamber of the Würzburg Regional Court (Landgericht Würzburg) sentenced the owner to six years' imprisonment and the former authorised signatory (Prokuristin) to two years suspended, and ordered the confiscation of around 20 million EUR; the judgment is not final.

What organisations can take from it

Bans on luxury goods to Russia are enforced with long prison sentences and confiscation of assets; authorised signatories are also personally liable.

Authority / court
Landgericht Würzburg (Wirtschaftsstrafkammer); Ermittlungen Zollfahndungsamt Essen und Staatsanwaltschaft Würzburg
Area of law
Sanctions and export control · Breaches of sanctions and embargoes
Legal basis
Außenwirtschaftsgesetz i. V. m. Russland-Embargoverordnung (EU) Nr. 833/2014 (gewerbsmäßig)
Action
Custodial sentence
Status of proceedings
unknown
Sector
Automotive
Culpability
intentional
Liability of senior managers
Owner (Andreas M.) six years' imprisonment; former authorised signatory (Inna W.) two years suspended.
Published
2 Mar 2026

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 USABreaches of sanctions and embargoes €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.

What organisations can take from it

Screen investors through to the beneficial owner and re-check them when new designations occur – nested structures do not protect against liability.

Relevance to training and awareness

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.

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

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19 Nov 2025 Former managing director in custody: machine tools to Russia via third countries GermanyBreaches of sanctions and embargoes Order

A 55-year-old former managing director from the Tübingen area is alleged to have supplied five machine tools worth around 1.7 million EUR to Russia via various third countries between October 2023 and December 2024. The Stuttgart Local Court (Amtsgericht Stuttgart) issued an arrest warrant and an asset freeze of around 1.5 million EUR; premises searched included a freight forwarder in Duisburg. The investigations by the Stuttgart public prosecutor's office and customs investigation office are ongoing (date = press release).

What organisations can take from it

Machine tools are among the core targets of the Russia sanctions; freight forwarders also come into the focus of customs investigators in cases of diverted shipments.

Relevance to training and awareness

Recognising circumvention via third countries (freight forwarding, sales)

Authority / court
Amtsgericht Stuttgart (Haftbefehl, Vermögensarrest); Staatsanwaltschaft Stuttgart; Zollfahndungsamt Stuttgart
Area of law
Sanctions and export control · Breaches of sanctions and embargoes
Legal basis
Außenwirtschaftsgesetz i. V. m. Verordnung (EU) Nr. 833/2014
Action
Order
Status of proceedings
unknown
Sector
Manufacturing and mechanical engineering
Liability of senior managers
Former managing director in pre-trial detention.
Published
19 Nov 2025

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 United KingdomBreaches of sanctions and embargoes €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.

What organisations can take from it

Anyone approving payments must also screen the recipient's bank against sanctions lists – and report breaches discovered without delay.

Relevance to training and awareness

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.

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 USABreaches of sanctions and embargoes €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.

What organisations can take from it

Urgent customer orders never justify skipping sanctions screening of carriers and of the aircraft or vessels used.

Relevance to training and awareness

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.

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

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8 Jul 2025 Freies Autohaus aus Lohra (Inhaber nicht genannt)Five years' imprisonment for smuggling 71 luxury cars to Russia GermanyBreaches of sanctions and embargoes €5m

The person responsible for an independent car dealership sold 71 luxury vehicles with a value of goods of around 5 million EUR to Russia, feigning lawful exports to third countries. Following investigations by the Frankfurt am Main public prosecutor's office and the Essen customs investigation office, the Marburg Regional Court (Landgericht Marburg) imposed five years' imprisonment and ordered the confiscation of around 5 million EUR; the judgment is not final.

What organisations can take from it

Feigned exports to third countries are exposed through customs data and payment flows – confiscation covers the entire value of the goods.

Authority / court
Landgericht Marburg; Ermittlungen Staatsanwaltschaft Frankfurt am Main und Zollfahndungsamt Essen
Area of law
Sanctions and export control · Breaches of sanctions and embargoes
Legal basis
Außenwirtschaftsgesetz i. V. m. Verordnung (EU) Nr. 833/2014 (Luxusgüterverbot)
Action
Custodial sentence
Status of proceedings
unknown
Sector
Automotive
Culpability
intentional
Liability of senior managers
The person responsible for the car dealership was personally sentenced to five years' imprisonment.
Published
11 Jul 2025

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 USABreaches of sanctions and embargoes €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.

What organisations can take from it

After an acquisition, roll out the sanctions compliance programme to the new foreign subsidiary immediately – the Cuba embargo applies to US-controlled subsidiaries worldwide.

Relevance to training and awareness

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.

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 USABreaches of sanctions and embargoes €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.

What organisations can take from it

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.

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 United KingdomBreaches of sanctions and embargoes €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.

What organisations can take from it

Information requests from sanctions authorities need a clear intake channel and deadline monitoring – merely missing the deadline is already an offence.

Relevance to training and awareness

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.

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 CanadaBreaches of sanctions and embargoes 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.

What organisations can take from it

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 USABreaches of sanctions and embargoes €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).

What organisations can take from it

Spare parts and software unlock codes for machines already delivered are also services relevant to sanctions – end customers behind dealers must be known.

Relevance to training and awareness

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.

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 USABreaches of sanctions and embargoes €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.

What organisations can take from it

Connect acquired freight forwarders to central screening quickly; until then, interim controls on origin and carrier are needed.

Relevance to training and awareness

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.

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 GermanyBreaches of sanctions and embargoes 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.

What organisations can take from it

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

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 NetherlandsBreaches of sanctions and embargoes €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.

What organisations can take from it

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.

Relevance to training and awareness

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

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

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17 Jul 2024 Electronics for Orlan-10 drones: 6 years 9 months' imprisonment for Saarland trader GermanyBreaches of sanctions and embargoes €880,000

From January 2020 to May 2023, a 59-year-old German-Russian supplied more than 120,000 electronic components in 54 instances to Russian arms manufacturers, including for the Orlan 10 reconnaissance drone, and after February 2022 named sham recipients in Hong Kong and Kyrgyzstan. The 7th Criminal Division of the Stuttgart Higher Regional Court (Oberlandesgericht Stuttgart, Ref. 7 St 3 BJs 119/23) sentenced him to six years and nine months, a co-defendant to one year and nine months suspended, and ordered the confiscation of 880,000 EUR.

What organisations can take from it

Electronics traders must check end users: standard components end up in Russian drones, and sham recipients in third countries do not protect against punishment.

Authority / court
Oberlandesgericht Stuttgart, 7. Strafsenat (Az. 7 St 3 BJs 119/23)
Area of law
Sanctions and export control · Breaches of sanctions and embargoes
Legal basis
§ 18 Außenwirtschaftsgesetz i. V. m. Verordnung (EU) Nr. 833/2014
Action
Custodial sentence
Status of proceedings
unknown
Sector
Retail and e-commerce
Culpability
intentional
Liability of senior managers
Managing director of two trading companies personally sentenced to imprisonment.
Published
17 Jul 2024

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