Compliance Radar

Who was sanctioned, and for what?

Fines, court rulings and incidents from Europe, North America, Latin America, Asia-Pacific, Middle East and Africa: 2,207 cases from 44 jurisdictions, each with an official source and checked against that source before publication. Filter by country, area of law and sector. Click a chart to drill down one level.

7cases from 2 jurisdictions
€63.3mTotal of monetary amounts
€17.9mLargest single case: a US subsidiary of a German asset manager
€6.8mMedian per case with an amount

Click a bar to drill down one level.

When?

per year, by date of decision
Trend
PeriodCasesTotal
20221€3.89m
20231€17.9m
20243€31m
20251€6.12m
20261€4.47m

7 cases

11 Aug 2026 Fiducian Investment Management Services LimitedFiducian: 7.3 million AUD for misleading ESG claims about an ethical fund AustraliaMisleading environmental and sustainability claims €4.47m

The Supreme Court of New South Wales, on application by the Australian Securities and Investments Commission (ASIC, Australia's corporate, markets and financial services regulator), imposed penalties totalling 7.3 million AUD on the fund manager: 2.3 million AUD for misleading statements (s 12DF ASIC Act) and 5 million AUD for breaching its duty of care and diligence as responsible entity (s 601FC(1)(b) Corporations Act). Between October 2019 and May 2024 the Diversified Social Aspirations Fund, marketed as socially responsible, held through underlying funds interests in companies that derived revenue from fossil fuels, among others, even though the product documents promised certain exclusions and ongoing monitoring; the company did not respond to investor concerns by amending its statements.

What organisations can take from it

A fund's sustainability promises require ongoing checks of its actual holdings; where they diverge, either the holdings or the statements must be changed.

Relevance to training and awareness

Substantiating ESG and ethical claims in product documents and fund marketing

Missing or inadequate training played a role in the decision.

Authority / court
Supreme Court of New South Wales (auf Antrag der Australian Securities and Investments Commission, ASIC)
Area of law
Environment and sustainability · Misleading environmental and sustainability claims
Legal basis
ASIC Act 2001 (Cth) s 12DF (Geldbuße nach s 12GBB); Corporations Act 2001 (Cth) s 601FC(1)(b) (Geldbuße nach s 1317G)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Culpability
negligent
Repeat case
no
Mitigating circumstances
Admissions, cooperation throughout the proceedings and contrition; since the proceedings began, an independent review of the product documents; no previous court findings.
Liability of senior managers
According to the agreed facts, senior management was involved (the company's then Executive Chair and Head of Investments).
Published
12 Aug 2026

Original amount 7,300,000 AUD, converted at the ECB reference rate of 11 Aug 2026.

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

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18 Mar 2025 LGSS Pty Ltd (Trustee des Active Super Fonds)ASIC: 10.5 million AUD against LGSS (Active Super) for greenwashing on exclusion screens AustraliaMisleading environmental and sustainability claims €6.12m

Following proceedings by the Australian Securities and Investments Commission (ASIC, the federal corporate and financial services regulator), the Federal Court of Australia on 18 March 2025 ordered LGSS Pty Ltd, trustee of the Active Super pension fund, to pay 10.5 million AUD and to send a notice of its misconduct to members and publish it on the fund's web pages. The fund had advertised that it excluded investments in, among others, gambling, coal mining and oil tar sands and, after the invasion of Ukraine, Russia, yet held such investments directly or indirectly; the court had found the breaches of the ban on misleading representations in June 2024.

What organisations can take from it

Advertised exclusion criteria must be reflected in all holdings, including indirect ones; deviations must be detected and corrected on an ongoing basis.

Relevance to training and awareness

Exclusion criteria and sustainability promises in fund marketing

Missing or inadequate training played a role in the decision.

Authority / court
Australian Securities and Investments Commission (ASIC) / Federal Court of Australia
Area of law
Environment and sustainability · Misleading environmental and sustainability claims
Legal basis
ASIC Act 2001 (Cth) ss 12DB(1)(a) und 12DF(1); Strafe nach s 12GBB, Veröffentlichungsanordnung nach s 12GLB
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
The court accepted some contrition, cooperation with ASIC through attendance at voluntary conferences and compliance improvements (including ESG and consumer law training for the board, executive leadership and staff, and an external review of internal controls), but gave less weight to contrition and cooperation because of how the case was defended; the merger with another fund trustee reduced the weight of specific deterrence.
Liability of senior managers
LGSS accepted in the proceedings that senior management was ultimately responsible for the absence of properly functioning systems to prevent false ESG representations; the proceedings were brought against the company only.
Published
18 Mar 2025

Original amount 10,500,000 AUD, converted at the ECB reference rate of 18 Mar 2025.

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

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8 Nov 2024 Invesco Advisers, Inc.Invesco Advisers: 17.5 million USD for inflated ESG integration percentages USAMisleading environmental and sustainability claims €16.2m

From 2020 to 2022, Invesco told clients that 70 to 94 per cent of the parent company's assets under management were ‘ESG integrated’, but counted passive ETFs that did not take ESG into account and had no written definition of ESG integration. The U.S. Securities and Exchange Commission (SEC) imposed 17.5 million USD, a censure and a cease-and-desist order.

What organisations can take from it

Sustainability metrics used in sales need a written definition and a traceable calculation.

Relevance to training and awareness

Verifiable metrics in ESG marketing

Authority / court
U.S. Securities and Exchange Commission (SEC)
Area of law
Environment and sustainability · Misleading environmental and sustainability claims
Legal basis
Investment Advisers Act of 1940
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Culpability
intentional
Published
8 Nov 2024

Original amount 17,500,000 USD, converted at the ECB reference rate of 8 Nov 2024.

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

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25 Sep 2024 an Australian fund managerAustralian fund manager: 12.9 million AUD for misleading ESG screens AustraliaMisleading environmental and sustainability claimsanonymised €7.93m

The Federal Court of Australia, on application by the Australian Securities and Investments Commission (ASIC, Australia's corporate, markets and financial services regulator), imposed a penalty of 12.9 million AUD because the fund manager claimed in product documents, on its website, in a media release and in online appearances that an ethically oriented global bond index fund excluded issuers with significant business activities in, among others, fossil fuels. According to the court, around 74% of the fund's securities by market value had in fact not been screened against the ESG criteria; the court had already found liability on 28 March 2024.

What organisations can take from it

ESG exclusions may only be advertised if they are actually applied to, and checked against, the entire portfolio.

Relevance to training and awareness

ESG screening and product claims: aligning marketing with the actual index methodology

Authority / court
Federal Court of Australia (auf Antrag der Australian Securities and Investments Commission, ASIC)
Area of law
Environment and sustainability · Misleading environmental and sustainability claims
Legal basis
ASIC Act 2001 (Cth) ss 12DF(1), 12DB(1)(a) und (e); Geldbuße nach ss 12GBA/12GBB
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
The company had identified the matter itself, reported it to ASIC and cooperated fully; the court applied a 25% discount for this.
Published
25 Sep 2024

Original amount 12,900,000 AUD, converted at the ECB reference rate of 25 Sep 2024.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 25 Sep 2026 · Direct link

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2 Aug 2024 an Australian superannuation trusteeSuperannuation trustee: AUD 11.3m penalty for misleading sustainability claims AustraliaMisleading environmental and sustainability claimsanonymised €6.8m

On its website the superannuation trustee promoted seven investment options of its superannuation fund marketed as sustainable as excluding companies involved in carbon-intensive fossil fuels, alcohol production and gambling; in fact six of the seven options held interests in such companies. Following admissions, the Court imposed AUD 11.3 million and ordered a court-prescribed notice on the website for six months. It was ASIC’s first greenwashing case before the Federal Court.

What organisations can take from it

Marketing claims about exclusion criteria need a control process that continuously checks actual portfolio holdings against the promises made.

Relevance to training and awareness

Review and sign-off of sustainability claims in marketing and on websites

Authority / court
Federal Court of Australia (auf Antrag der Australian Securities and Investments Commission, ASIC)
Area of law
Environment and sustainability · Misleading environmental and sustainability claims
Legal basis
ss 12DB(1)(a), 12DF(1) ASIC Act 2001 (Cth)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Repeat case
no
Mitigating circumstances
Early admission, full cooperation with ASIC, removal of the statements and clearer disclosure in an information booklet from April 2023.
Liability of senior managers
According to the Court’s findings, persons at senior management level were involved; there were no mandatory sign-off processes for website content.
Published
2 Aug 2024

Original amount 11,300,000 AUD, converted at the ECB reference rate of 2 Aug 2024.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 2 Aug 2026 · Direct link

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25 Sep 2023 a US subsidiary of a German asset managerUS asset manager: 19 million USD for misleading ESG statements USAMisleading environmental and sustainability claimsanonymised €17.9m

From 2018 until the end of 2021, the subsidiary of a German major bank presented ESG as part of its ‘DNA’ but did not implement the ESG integration policies it had promised. It is paying 19 million USD for the ESG misstatements; in separate proceedings over deficiencies in its anti-money laundering programme, a further 6 million USD was added.

What organisations can take from it

ESG marketing statements must be backed by processes that are actually practised and documented; otherwise they become a regulatory risk.

Relevance to training and awareness

Truthful sustainability communication in sales and marketing

Authority / court
U.S. Securities and Exchange Commission (SEC)
Area of law
Environment and sustainability · Misleading environmental and sustainability claims
Legal basis
Sections 206(2), 206(4) Investment Advisers Act; Rules 206(4)-7 und 206(4)-8
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
25 Sep 2023

Original amount 19,000,000 USD, converted at the ECB reference rate of 25 Sep 2023.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 25 Sep 2025 · Direct link

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22 Nov 2022 a large US asset managerAsset manager: 4 million USD for failing to follow ESG processes USAMisleading environmental and sustainability claimsanonymised €3.89m

From 2017 to 2020, the asset manager did not comply with its own ESG research policies for two ESG funds and one separately managed account strategy; questionnaires were often completed only after securities had been selected. At the same time, policies were described to third parties that were not consistently applied. The U.S. Securities and Exchange Commission (SEC) imposed 4 million USD, a censure and a cease-and-desist order.

What organisations can take from it

Companies that market products as ESG must actually and demonstrably carry out the described review processes before the investment decision.

Relevance to training and awareness

Compliance with internal ESG processes in the investment process

Authority / court
U.S. Securities and Exchange Commission (SEC)
Area of law
Environment and sustainability · Misleading environmental and sustainability claims
Legal basis
Section 206(4) Investment Advisers Act of 1940 und Rule 206(4)-7
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Published
22 Nov 2022

Original amount 4,000,000 USD, converted at the ECB reference rate of 22 Nov 2022.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 22 Nov 2024 · Direct link

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