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.
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per year, by date of decision| Period | Cases | Total |
|---|---|---|
| 2022 | 1 | €3.89m |
| 2023 | 1 | €17.9m |
| 2024 | 3 | €31m |
| 2025 | 1 | €6.12m |
| 2026 | 1 | €4.47m |
7 cases
11 Aug 2026 Fiducian Investment Management Services LimitedFiducian: 7.3 million AUD for misleading ESG claims about an ethical fund €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.
A fund's sustainability promises require ongoing checks of its actual holdings; where they diverge, either the holdings or the statements must be changed.
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.
- Supreme Court of NSW – In the matter of Fiducian Investment Management Services Pty Ltd [2026] NSWSC 959 (Decision date 11.08.2026) Court decision
- ASIC 26-191MR – Court orders Fiducian Investment Management Services to pay $7.3 million penalty over operation of ESG fund (12.08.2026) Press release of an authority
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 €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.
Advertised exclusion criteria must be reflected in all holdings, including indirect ones; deviations must be detected and corrected on an ongoing basis.
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 €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.
Sustainability metrics used in sales need a written definition and a traceable calculation.
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.
- SEC Charges Invesco Advisers for Making Misleading Statements About Supposed Investment Considerations Press release of an authority
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 €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.
ESG exclusions may only be advertised if they are actually applied to, and checked against, the entire portfolio.
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 €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.
Marketing claims about exclusion criteria need a control process that continuously checks actual portfolio holdings against the promises made.
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 €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.
ESG marketing statements must be backed by processes that are actually practised and documented; otherwise they become a regulatory risk.
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.
- SEC, Pressemitteilungen (Übersicht) (Entscheidung 2023) Press release of an authority
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 €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.
Companies that market products as ESG must actually and demonstrably carry out the described review processes before the investment decision.
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.
- SEC, Pressemitteilungen (Übersicht) (Entscheidung 2022) Press release of an authority
Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 22 Nov 2024 · Direct link