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.

54cases from 18 jurisdictions
€6.15bnTotal of monetary amounts (49 cases with an amount)
€4.75bnLargest single case: Purdue Pharma L.P.
€1.26mMedian per case with an amount

Click a bar to drill down one level.

Where?

by region

All jurisdictions

  1. USA €5.27bn 86 % · 16 cases
  2. EU €708.1m 12 % · 16 cases
  3. Brazil €121.7m 2 % · 4 cases
  4. United Kingdom €35.9m 1 % · 9 cases
  5. Japan €4.18m 0 % · 2 cases
  6. Canada €2.26m 0 % · 3 cases
  7. South Korea €1.9m 0 % · 1 case
  8. Switzerland €645,231 0 % · 1 case
  9. South Africa €236,068 0 % · 1 case
  10. New Zealand €223,678 0 % · 1 case

What for?

by area of law

All areas of law

  1. Bribery and corruption €5.14bn 84 % · 10 cases
  2. Competition law €951.5m 15 % · 20 cases
  3. Environment and sustainability €24.3m 0 % · 7 cases
  4. Sanctions and export control €22.3m 0 % · 3 cases
  5. Health and safety and employment law €5.75m 0 % · 6 cases
  6. Consumer protection and online retail €4.18m 0 % · 2 cases
  7. Capital markets and financial supervision €2.48m 0 % · 4 cases
  8. Whistleblower protection €210,202 0 % · 1 case
  9. Supply chain and human rights – 0 % · 1 case

Who?

by company
  1. Purdue Pharma L.P. €4.75bn 77 % · 1 case
  2. Anonymised companies €546m 9 % · 17 cases
  3. Teva Pharmaceutical Industries (Teva-Gruppe) €462.6m 8 % · 1 case
  4. Gilead Sciences, Inc. €177.8m 3 % · 1 case
  5. Pfizer Inc. (für die Tochter Biohaven Pharmaceutical Holding Company Ltd.) €57.1m 1 % · 1 case
  6. Novamont S.p.A., Eni S.p.A. €32.1m 1 % · 1 case
  7. Dompé U.S. Inc. €27.5m 0 % · 1 case
  8. Vifor Pharma UK Limited u. a. (CSL-Konzern) €27.4m 0 % · 1 case
  9. The Chemours Company; The Chemours Company FC, LLC €19.8m 0 % · 1 case
  10. Takeda Pharmaceuticals U.S.A., Inc. €11.7m 0 % · 1 case
  11. 27 more€40.8m

When?

per year, by date of decision
Trend
PeriodCasesTotal
20226€284.7m
20238€226.1m
20246€506.7m
202518€313.4m
202616€4.82bn

54 cases

10 Sep 2026 Dompé U.S. Inc.Dompé U.S.: 32 million USD – Medicare patients’ co-payments covered via foundations USAGifts, hospitality and benefits €27.5m

From 2018 to 2021, the pharmaceutical manufacturer allegedly used two patient assistance foundations to fund Medicare beneficiaries’ co-payments for its drug Oxervate in order to promote its sales. Following a self-disclosure, Dompé paid 32 million USD.

What organisations can take from it

Benefits flowing to customers via foundations or other third parties remain benefits provided by the company – donations to patient assistance programmes require strict independence.

Relevance to training and awareness

Benefits to patients and customers via third parties

Authority / court
U.S. Department of Justice / U.S. Attorney's Office, District of Massachusetts
Area of law
Bribery and corruption · Gifts, hospitality and benefits
Legal basis
Anti-Kickback Statute (42 U.S.C. § 1320a-7b(b)); False Claims Act (31 U.S.C. §§ 3729 ff.)
Action
Other
Status of proceedings
final
Sector
Chemicals and pharmaceuticals
Mitigating circumstances
Self-disclosure.

Original amount 32,000,000 USD, converted at the ECB reference rate of 10 Sep 2026.

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

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25 Aug 2026 ExxonMobil Chemical LimitedExxonMobil Chemical: 267,000 GBP for five hydrocarbon leaks at Fife ethylene plant United KingdomWorkplace safety and accidents €312,098

Between February 2018 and September 2019, five leaks of highly flammable hydrocarbons occurred at the Mossmorran major hazard site (COMAH upper tier), all caused by corrosion under insulation; around 82 tonnes escaped in one leak. During a routine inspection in May 2019, inspectors of the Health and Safety Executive (HSE) smelled escaping gas – the company had known about this leak for around four months and had continued production without additional precautions. The inspection arrangements for insulated pipework were inadequate; fine of 267,000 GBP.

What organisations can take from it

Recurring damage patterns must change the inspection concept – visual inspections from the ground are not sufficient for insulated pipework.

Authority / court
Health and Safety Executive (Kirkcaldy Sheriff Court)
Area of law
Health and safety and employment law · Workplace safety and accidents
Legal basis
Provision and Use of Work Equipment Regulations 1998, reg. 6(2); Health and Safety at Work etc. Act 1974, s. 33(1)(c)
Action
Fine
Status of proceedings
final
Sector
Chemicals and pharmaceuticals
Employees
10,000 or more
Published
26 Aug 2026

Original amount 267,000 GBP, converted at the ECB reference rate of 25 Aug 2026.

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

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14 Aug 2026 Henkel AG & Co. KGaAHenkel/Liquid Nails: court blocks takeover of Loctite’s main competitor USAMerger control Order

Henkel wanted to buy the construction adhesive brand Liquid Nails for 725 million USD from the financial investor American Industrial Partners, thereby taking over the main competitor of its Loctite brand. After a seven-day trial, the federal court, on application by the Federal Trade Commission (FTC), issued a permanent injunction against the acquisition.

What organisations can take from it

Acquiring the closest competitor carries a high risk of prohibition, even at a moderate deal volume.

Authority / court
U.S. District Court for the Southern District of New York (auf Antrag der FTC)
Area of law
Competition law · Merger control
Legal basis
Section 7 Clayton Act; Section 13(b) FTC Act (Permanent Injunction)
Action
Order
Status of proceedings
unknown
Sector
Chemicals and pharmaceuticals
Employees
10,000 or more
Published
17 Aug 2026

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

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10 Aug 2026 Veloxis Pharmaceuticals Inc.Veloxis: over 46 million USD – luxury trips, dinners and gifts for transplant teams USAGifts, hospitality and benefits Other

From 2016 to 2023, Veloxis provided transplant professionals with expensive meals and alcohol, trips and stays at luxury resorts, gifts and consultancy fees without consideration, and paid specialty pharmacies concealed remuneration in order to promote prescriptions and purchases of the immunosuppressant Envarsus XR. The company entered into a Deferred Prosecution Agreement with a criminal payment of more than 10 million USD, is paying 34.45 million USD under civil law (21,211,251 USD to the federal government, 13,238,749 USD to states) and a penalty of 1.55 million USD under the Sunshine Act (Open Payments) – the highest to date – totalling over 46 million USD.

What organisations can take from it

Invitations and gifts to decision-makers must not only be limited but also fully reported to transparency registers.

Relevance to training and awareness

Gifts, travel and hospitality for healthcare professionals; transparency reporting

Authority / court
U.S. Department of Justice / U.S. Attorney's Office, District of Massachusetts
Area of law
Bribery and corruption · Gifts, hospitality and benefits
Legal basis
Anti-Kickback Statute; False Claims Act; Physician Payments Sunshine Act (Open Payments)
Action
Other
Status of proceedings
final
Sector
Chemicals and pharmaceuticals

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

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3 Aug 2026 Guangxi Kelun Pharmaceutical Co., Ltd.UFLPA list: antibiotics manufacturer Guangxi Kelun Pharmaceutical added USAForced and child labour Order

The U.S. Forced Labor Enforcement Task Force (FLETF) listed the manufacturer of cephalosporin antibiotics because it sources antibiotic intermediates from Yili Chuanning Biotechnology in Xinjiang. The company's goods are therefore presumed to have been produced with forced labour on import into the US unless the importer rebuts this.

What organisations can take from it

Pharmaceutical companies must be able to trace their supply chains back to active ingredient intermediates.

Authority / court
U.S. Department of Homeland Security (Forced Labor Enforcement Task Force)
Area of law
Supply chain and human rights · Forced and child labour
Legal basis
Uyghur Forced Labor Prevention Act, Section 2(d)(2)(B)(v)
Action
Order
Status of proceedings
unknown
Sector
Chemicals and pharmaceuticals
Published
3 Aug 2026

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

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20 Jul 2026 EyePoint Pharmaceuticals, Inc.EyePoint: 4.66 million USD – kickbacks to surgery centres for purchasing an eye medicine USACommercial bribery €4.08m

Between January 2019 and March 2023, the pharmaceutical manufacturer allegedly paid kickbacks to ambulatory surgery centres to induce them to purchase and use the injectable drug DEXYCU for cataract surgery. To resolve the False Claims Act allegations, EyePoint paid 4,657,463.18 USD and entered into a Corporate Integrity Agreement with HHS-OIG.

What organisations can take from it

Discounts, payments or services to institutions that make purchasing decisions require a documented consideration at market value.

Relevance to training and awareness

Granting benefits to customers and purchasing decision-makers

Authority / court
U.S. Department of Justice
Area of law
Bribery and corruption · Commercial bribery
Legal basis
Anti-Kickback Statute (42 U.S.C. § 1320a-7b(b)); False Claims Act (31 U.S.C. §§ 3729 ff.)
Action
Other
Status of proceedings
final
Sector
Chemicals and pharmaceuticals

Original amount 4,657,463.18 USD, converted at the ECB reference rate of 20 Jul 2026.

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

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24 Jun 2026 The Chemours Company; The Chemours Company FC, LLCChemours: USD 22.5m civil penalty in PFAS settlement with EPA and West Virginia USAEmissions and permits €19.8m

The EPA, the US Department of Justice and West Virginia's environmental agency reached a settlement (consent decree) with Chemours over PFAS discharges into the Cape Fear, Delaware and Ohio rivers, some made without and some in breach of discharge permits, together with TSCA and RCRA violations at four plants. Chemours will pay a civil penalty of 22,500,000 USD in three annual instalments of 7,500,000 USD and carry out remedial measures, including drinking water supply, PFAS controls and a USD 90m mitigation programme, which the EPA puts at over USD 450m in total. The settlement was lodged with the court on 24 June 2026 and is subject to public comment and court approval. The authority allegedly made the findings set out here; this account is not based on a final judgment. The decision is not final.

What organisations can take from it

PFAS manufacturers must continuously check every discharge against their permits – unregulated flows lead to penalties and costly obligations towards local residents.

Relevance to training and awareness

Discharge permits and PFAS emissions

Authority / court
U.S. Environmental Protection Agency (EPA) / U.S. Department of Justice mit West Virginia Department of Environmental Protection (U.S. District Court, Southern District of West Virginia)
Area of law
Environment and sustainability · Emissions and permits
Legal basis
Clean Water Act (NPDES); Resource Conservation and Recovery Act; Toxic Substances Control Act; West Virginia Water Pollution Control Act
Action
Fine
Status of proceedings
not yet final
Sector
Chemicals and pharmaceuticals
Mitigating circumstances
The civil penalty was set on the basis of the company's ability to pay.
Published
24 Jun 2026

Original amount 22,500,000 USD, converted at the ECB reference rate of 24 Jun 2026.

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

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23 Jun 2026 Denka Performance Elastomer, LLCDenka Performance Elastomer: USD 996,703 over hazardous waste at neoprene plant USAWaste and hazardous substances €874,915

The EPA (Region 6) issued a Consent Agreement and Final Order against Denka Performance Elastomer over RCRA violations at its neoprene plant in LaPlace (Louisiana): missing waste determinations, breaches of land disposal restrictions and treatment and storage of hazardous waste without a permit. Denka will pay 996,703.35 USD and must clean out a brine pit and its ancillary equipment; if the currently idle plant resumes operations, further requirements apply, including on waste inventory, containers, training and protective equipment. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

Every waste stream needs a documented determination of whether it is hazardous – without it there is no basis for lawful storage, treatment and disposal.

Relevance to training and awareness

Classification and storage of hazardous waste

Missing or inadequate training played a role in the decision.

Authority / court
U.S. Environmental Protection Agency (EPA), Region 6
Area of law
Environment and sustainability · Waste and hazardous substances
Legal basis
Resource Conservation and Recovery Act (RCRA), Docket RCRA-06-2025-0910
Action
Fine
Status of proceedings
final
Sector
Chemicals and pharmaceuticals
Repeat case
yes
Published
2 Jul 2026

Original amount 996,703.35 USD, converted at the ECB reference rate of 23 Jun 2026.

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

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14 May 2026 Takeda Pharmaceuticals U.S.A., Inc.Takeda: 13.7 million USD – speaker fees and luxury meals for prescribing physicians USAGifts, hospitality and benefits €11.7m

From 2014 to 2020, Takeda allegedly selected physicians specifically for its speaker programme for the antidepressant Trintellix and provided them with fees and meals at expensive restaurants to promote prescriptions; some participants attended the same event several times without any educational benefit. Takeda paid 13,670,921 USD.

What organisations can take from it

Speaker programmes need a demonstrable educational purpose – repeated attendance and expensive hospitality turn them into inducements.

Relevance to training and awareness

Invitations, hospitality and fees for healthcare professionals

Authority / court
U.S. Department of Justice / U.S. Attorney's Office, Eastern District of California
Area of law
Bribery and corruption · Gifts, hospitality and benefits
Legal basis
Anti-Kickback Statute (42 U.S.C. § 1320a-7b(b)); False Claims Act (31 U.S.C. §§ 3729 ff.)
Action
Other
Status of proceedings
final
Sector
Chemicals and pharmaceuticals
Employees
10,000 or more

Original amount 13,670,921 USD, converted at the ECB reference rate of 14 May 2026.

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

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13 May 2026 NaphtachimieMarseille: environmental CJIP with Naphtachimie for €1.2m after oil leaks at Lavéra FranceEmissions and permits €1.2m

Pyrolysis oil leaked twice at the Lavéra petrochemical site in Martigues: around 50 tonnes in July 2018 through a failed seal into the Anse d'Auguette, part of which reached the sea, and around one tonne in April 2022 through a corroded seawater pipe, of which some 500 kg reached the Anse d'Auguette. Naphtachimie therefore concluded an environmental CJIP (convention judiciaire d'intérêt public, French deferred prosecution agreement) with the Marseille public prosecutor; it pays a public interest fine of 1,200,000 EUR, compensates two environmental associations and will trial, at its own expense, a biological clean-up of the Anse d'Auguette; validated on 13 May 2026.

What organisations can take from it

Seals and pipes at plants handling substances hazardous to water must be inspected proactively; leaks lead to fines and remediation duties.

Relevance to training and awareness

Maintenance and leak prevention at industrial sites near water

Authority / court
Parquet de Marseille (Procureur de la République); Validierung durch den Präsidenten des Tribunal judiciaire de Marseille
Area of law
Environment and sustainability · Emissions and permits
Legal basis
Art. 41-1-3 Code de procédure pénale (pollution des eaux)
Action
Fine
Status of proceedings
final
Sector
Chemicals and pharmaceuticals
Published
26 May 2026

Checked against the official source on 2 Oct 2026 · Direct link

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28 Apr 2026 Purdue Pharma L.P.Purdue Pharma: 5.544 billion USD penalty – including kickbacks via the speaker programme USAGifts, hospitality and benefits €4.75bn

Following its 2020 guilty plea, the opioid manufacturer was sentenced in Newark to a criminal fine of 3.544 billion USD (asserted in the insolvency proceedings) and forfeiture of 2 billion USD; up to 1.775 billion USD can be credited against the forfeiture if Purdue emerges from insolvency as a public benefit company. Purdue had deceived the DEA and paid kickbacks to prescribers via its speaker programme and to an electronic health records platform in order to increase opioid prescriptions.

What organisations can take from it

Fee programmes for customers who drive revenue can become part of a criminal overall scheme – with consequences that threaten the company’s existence.

Relevance to training and awareness

Speaker fees and benefits for prescribing physicians

Authority / court
U.S. District Court, District of New Jersey (Anklage: U.S. Department of Justice)
Area of law
Bribery and corruption · Gifts, hospitality and benefits
Legal basis
Verschwörung zum Betrug der USA und zur Verletzung des Food, Drug, and Cosmetic Act; zwei Fälle Verschwörung zur Verletzung des Anti-Kickback Statute (Schuldbekenntnis vom 24.11.2020)
Action
Fine
Status of proceedings
unknown
Sector
Chemicals and pharmaceuticals
Culpability
intentional

Original amount 5,544,000,000 USD, converted at the ECB reference rate of 28 Apr 2026.

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

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21 Apr 2026 Industrial Chemicals LimitedIndustrial Chemicals: 3.8 million GBP after caustic soda burns – one leg amputated United KingdomWorkplace safety and accidents €4.37m

In 2019, an employee stepped into a puddle of caustic soda; his safety boots offered no protection, and his leg had to be amputated below the knee. In 2022, another worker suffered chemical burns during manual decanting. The Health and Safety Executive (HSE) found leaking pipes and valves, a lack of maintenance, no risk assessment for decanting and untested safety footwear; fine of 3.8 million GBP plus 124,748 GBP in costs. According to the annual accounts filed with the UK companies register for financial year 2024, the company had around 469 employees.

What organisations can take from it

Leaks of hazardous substances are not a normal state of affairs – maintenance, spill management and tested protective equipment go hand in hand.

Relevance to training and awareness

Handling corrosive hazardous substances and PPE

Authority / court
Health and Safety Executive (Southwark Crown Court)
Area of law
Health and safety and employment law · Workplace safety and accidents
Legal basis
Control of Substances Hazardous to Health Regulations 2002, reg. 7(1)
Action
Fine
Status of proceedings
final
Sector
Chemicals and pharmaceuticals
Employees
250 to 999
Published
24 Apr 2026

Original amount 3,800,000 GBP, converted at the ECB reference rate of 21 Apr 2026.

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

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28 Jan 2026 Syngenta LtdSyngenta: 400,000 GBP after uncontrolled release of high-pressure steam during maintenance United KingdomWorkplace safety and accidents €460,564

While flange bolts were being removed from a steam trap in November 2023, a corroded isolation valve failed and high-pressure steam escaped; the contractor's fitter narrowly escaped serious injury. The agrochemicals group had not maintained work equipment and had not assessed the risk despite known corrosion (only single instead of double isolation). The Health and Safety Executive (HSE) prosecution resulted in a fine of 400,000 GBP plus 8,288 GBP in costs.

What organisations can take from it

Known corrosion requires safer isolation procedures – routine tasks must not mask risks.

Relevance to training and awareness

Isolation and shut-off during maintenance

Authority / court
Health and Safety Executive (Leeds Magistrates' Court)
Area of law
Health and safety and employment law · Workplace safety and accidents
Legal basis
Provision and Use of Work Equipment Regulations 1998, reg. 5(1); Management of Health and Safety at Work Regulations 1999, reg. 3(1)
Action
Fine
Status of proceedings
final
Sector
Chemicals and pharmaceuticals
Employees
10,000 or more
Published
28 Jan 2026

Original amount 400,000 GBP, converted at the ECB reference rate of 28 Jan 2026.

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

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13 Jan 2026 Estee Lauder Cosmetics Ltd.Estee Lauder Cosmetics: 750,000 CAD fine for unreported PFAS in eyeliners Canada, ONWaste and hazardous substances €463,765

A routine inspection in 2023 found that the company was selling eyeliners containing the PFAS substance perfluorononyl dimethicone without submitting the required notification of a ‘significant new activity’; a subsequent compliance order was not complied with. The court imposed 750,000 CAD; the company must inform its shareholders and is listed in the Environmental Offenders Registry.

What organisations can take from it

Product development and regulatory affairs must check new substances for notification requirements before market launch; regulatory orders must be implemented within the deadline.

Relevance to training and awareness

Chemical notification and approval obligations for product launches

Authority / court
Ontario Court of Justice (Ermittlungen: Environment and Climate Change Canada)
Area of law
Environment and sustainability · Waste and hazardous substances
Legal basis
Canadian Environmental Protection Act, 1999 (Significant New Activity, Compliance Order)
Action
Fine
Status of proceedings
unknown
Sector
Chemicals and pharmaceuticals
Published
2 Feb 2026

Original amount 750,000 CAD, converted at the ECB reference rate of 13 Jan 2026.

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

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7 Jan 2026 Superior General Partner Inc.Superior General Partner: 1.35 million CAD fine for sodium chlorite in river and late reporting Canada, QCWaste and hazardous substances €836,690

In 2019, as a result of an equipment defect, sodium chlorite entered the Rivière du Lièvre twelve times from the ERCO Mondial chemical plant in Gatineau; in the last incident, the authorities were only informed after five days. The company was fined 1.35 million CAD.

What organisations can take from it

Reporting obligations for releases of substances apply immediately; those who wait for days incur additional liability.

Relevance to training and awareness

Immediate reporting of environmental incidents to the authorities

Authority / court
Court of Québec (Ermittlungen: Environment and Climate Change Canada)
Area of law
Environment and sustainability · Waste and hazardous substances
Legal basis
Fisheries Act (Einbringen schädlicher Stoffe; unterlassene sofortige Meldung)
Action
Fine
Status of proceedings
unknown
Sector
Chemicals and pharmaceuticals
Published
8 Jan 2026

Original amount 1,350,000 CAD, converted at the ECB reference rate of 7 Jan 2026.

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

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6 Jan 2026 Futamura Chemical UK LtdHydrogen sulphide in drainage system: film manufacturer pays 200,000 GBP after death United KingdomWorkplace safety and accidents €230,867

At the Wigton plant in 2021 an employee collapsed in a pump room after exposure to gas and died; a delivery driver who tried to help also lost consciousness. According to the investigation, the cellulose film manufacturer had not assessed that hydrogen sulphide from the production process could enter the drainage system and be released there; fine of 200,000 GBP plus 20,000 GBP in costs. According to its 2025 annual accounts, the company had an average of 283 employees.

What organisations can take from it

Cover all exposure pathways in risk assessments for hazardous substances – including effluent and drainage systems.

Authority / court
Warrington Magistrates' Court (Anklage: Health and Safety Executive)
Area of law
Health and safety and employment law · Workplace safety and accidents
Legal basis
Section 2(1) und 3(1) Health and Safety at Work etc. Act 1974
Action
Fine
Status of proceedings
unknown
Sector
Chemicals and pharmaceuticals
Employees
250 to 999
Published
8 Jan 2026

Original amount 200,000 GBP, converted at the ECB reference rate of 6 Jan 2026.

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

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28 Oct 2025 ExxonMobil Chemical LimitedExxonMobil Chemical: 176,000 GBP fine for six days of continuous flaring in Fife United KingdomEmissions and permits €200,913

Following a loss of steam in April 2019, the ethylene plant in Fife flared for almost a week; the smoke significantly exceeded permit limits, and the Scottish Environment Protection Agency (SEPA) received over 900 complaints. Existing procedures and emergency plans should have prevented the incident but were not adequately followed. The company pleaded guilty and was fined 176,000 GBP.

What organisations can take from it

Emergency plans only protect if staff apply them consistently in an emergency – regular drills are part of permit compliance.

Relevance to training and awareness

Compliance with operating and emergency procedures in industrial plants

Authority / court
Kirkcaldy Sheriff Court (Ermittlungen: Scottish Environment Protection Agency, SEPA)
Area of law
Environment and sustainability · Emissions and permits
Legal basis
Regulation 67(1)(b) Pollution Prevention and Control (Scotland) Regulations 2012; Section 2 Pollution Prevention and Control Act 1999
Action
Fine
Status of proceedings
unknown
Sector
Chemicals and pharmaceuticals
Employees
10,000 or more
Culpability
negligent
Published
28 Oct 2025

Original amount 176,000 GBP, converted at the ECB reference rate of 28 Oct 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. According to the annual accounts filed with the UK companies register for financial year 2025, the company had around 280 employees.

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
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

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1 Aug 2025 P&G Japan G.K. (P&Gジャパン合同会社)P&G Japan: order over unsubstantiated anti-mould claims for a Febreze product JapanMisleading advertising and pricing Order

P&G Japan advertised its 'Febreze bathroom anti-mould' product (ファブリーズ お風呂用防カビ剤), among other things on the packaging from April 2022 to May 2023, by claiming that simply placing it in the bathroom would prevent black mould for around six weeks. The documents submitted did not substantiate this effect, so the advertising was deemed misleading; the order required a corrective notice, measures to prevent recurrence and cessation.

What organisations can take from it

Anyone promising an effect must hold robust evidence before advertising; without it, the claim is deemed misleading.

Relevance to training and awareness

Substantiating efficacy claims in advertising

Authority / court
Consumer Affairs Agency (消費者庁, CAA)
Area of law
Consumer protection and online retail · Misleading advertising and pricing
Legal basis
Art. 7 Abs. 1 und 2 i. V. m. Art. 5 Nr. 1 Act against Unjustifiable Premiums and Misleading Representations (不当景品類及び不当表示防止法, Gesetz Nr. 134/1962)
Action
Order
Status of proceedings
unknown
Sector
Chemicals and pharmaceuticals
Published
1 Aug 2025

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

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25 Jul 2025 Tamro Eesti OÜTamro Eesti: order against unfair payment terms for food supplements EstoniaAbuse of market power Order

In consignment agreements, the pharmaceutical wholesaler had made payment to suppliers of food supplements dependent on subsequent resale (payment period over 30 days) and had reserved the right to hold suppliers liable for spoiled goods. The Konkurentsiamet (Estonian Competition Authority) found infringements of the act on unfair trading practices in the food supply chain and ordered amended contractual terms.

What organisations can take from it

Purchasing terms in the food sector – including for food supplements – must comply with the 30-day payment period and the prohibition on shifting risk.

Authority / court
Konkurentsiamet (Estnische Wettbewerbsbehörde)
Area of law
Competition law · Abuse of market power
Legal basis
§ 4 Abs. 1 und 2, § 5 Abs. 2, § 7 Abs. 1 PTEKS (UTP-Richtlinie (EU) 2019/633)
Action
Order
Status of proceedings
unknown
Sector
Chemicals and pharmaceuticals

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

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4 Jul 2025 Alchem International Pvt. Ltd. und Alchem International (H.K.) LimitedAlchem: €489,000 fine for taking part in the SNBB pharmaceutical ingredient cartel EU levelCartels and collusion €489,000

According to the European Commission's findings, Alchem took part from 1 November 2005 to 12 February 2018 in an EEA-wide cartel concerning the active ingredient N-butylbromide scopolamine (SNBB), involving minimum prices, quotas and exchanges of sensitive information. Unlike the other participants, who were subject to a settlement decision in October 2023, Alchem declined to settle and received a fine of 489,000 EUR without any reduction.

What organisations can take from it

Suppliers of active pharmaceutical ingredients are also subject to the cartel prohibition; those who do not cooperate forgo reductions.

Relevance to training and awareness

Price-fixing and quota agreements between competitors

Authority / court
Europäische Kommission
Area of law
Competition law · Cartels and collusion
Legal basis
Art. 101 AEUV; Art. 53 EWR-Abkommen
Action
Fine
Status of proceedings
unknown
Sector
Chemicals and pharmaceuticals
Published
4 Jul 2025

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

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24 Jun 2025 Grifols, S.A.CNMV: €1m fine on Grifols for flawed financial reports and performance measures SpainDisclosure and reporting obligations €1m

The Comisión Nacional del Mercado de Valores (CNMV, Spanish securities market supervisor) imposed two fines totalling 1,000,000 EUR on Grifols: 800,000 EUR because the consolidated financial statements for 2021 to 2023 and the 2023 half-year report contained inaccurate or incomplete information under IFRS, and 200,000 EUR for misleading information on the calculation of alternative performance measures (APMs) in the management reports. The company waived administrative appeals.

What organisations can take from it

Alternative performance measures must be calculated transparently and traceably; the issuer is liable for incorrect financial information.

Relevance to training and awareness

Accuracy of financial reports and alternative performance measures

Authority / court
Comisión Nacional del Mercado de Valores (CNMV)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Art. 282.1.b) und Art. 292.1.f) Ley 6/2023 de los Mercados de Valores y de los Servicios de Inversión
Action
Fine
Status of proceedings
unknown
Sector
Chemicals and pharmaceuticals
Employees
10,000 or more
Liability of senior managers
Measures against individuals are not reported here.
Published
6 Aug 2025

Checked against the official source on 28 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 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
Measures against individuals are not reported here.
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 28 Sep 2026 · Version 2 · Direct link

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10 Jun 2025 Novamont S.p.A., Eni S.p.A.AGCM fines Novamont and Eni €32.1m over exclusivity ties in bioplastics ItalyAbuse of market power €32.1m

According to the AGCM, from at least January 2018 to December 2023 Novamont tied film producers to its bioplastic Mater-Bi through exclusive or semi-exclusive purchasing obligations and tied retail chains to carrier bags made by its licensees, thereby excluding competitors in bio-compounds for lightweight and very lightweight plastic carrier bags (Art. 102 TFEU). Novamont must pay 30,359,000 EUR (capped at the 10% turnover limit); for the period after its acquisition by the Eni group on 18 October 2023, Novamont and Eni are jointly and severally liable for a further 1,701,052.08 EUR, a total of 32,060,052.08 EUR.

What organisations can take from it

A compliance programme must address the specific competition risks of the business, such as exclusivity clauses used by a strong supplier, or it will not reduce the fine.

Relevance to training and awareness

Exclusivity clauses of dominant suppliers and effective compliance programmes

Missing or inadequate training played a role in the decision.

Authority / court
Autorità Garante della Concorrenza e del Mercato (AGCM)
Area of law
Competition law · Abuse of market power
Legal basis
Art. 102 AEUV; Art. 15 Legge n. 287/1990
Action
Fine
Status of proceedings
unknown
Sector
Chemicals and pharmaceuticals
Mitigating circumstances
None recognised: the compliance programme of the Eni group, which Novamont joined in October 2023, had not worked effectively because training and controls covered other topics and exclusive contracts continued to be concluded; the AGCM considered Novamont's earlier programme manifestly inadequate, partly because its competition law manual did not specifically address exclusive purchasing obligations among the forms of abuse.
Published
24 Jun 2025

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

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23 May 2025 Vifor Pharma UK Limited u. a. (CSL-Konzern)CMA: Vifor pays GBP 23m to the NHS after suspected disparagement of a rival United KingdomAbuse of market power €27.4m

The CMA had investigated whether, between 2010 and 2024, Vifor abused a suspected dominant position in high-dose intravenous iron by spreading potentially misleading claims about the safety of the rival product Monofer compared with its own Ferinject. It accepted binding commitments: a voluntary payment of GBP 23m to the NHS, a corrective communication campaign aimed at healthcare professionals and additional compliance measures; no infringement was found.

What organisations can take from it

Safety claims about competing products made to healthcare professionals must be substantiated and balanced – disparagement can be pursued as an abuse of market power.

Relevance to training and awareness

Claims about competitor products in pharmaceutical marketing

Authority / court
Competition and Markets Authority (CMA)
Area of law
Competition law · Abuse of market power
Legal basis
Chapter II prohibition, section 18(1) Competition Act 1998 (Verdacht); Verpflichtungszusagen nach section 31A Competition Act 1998
Action
Other
Status of proceedings
final
Sector
Chemicals and pharmaceuticals
Published
23 May 2025

Original amount 23,000,000 GBP, converted at the ECB reference rate of 23 May 2025.

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

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28 Apr 2025 Gilead Sciences, Inc.Gilead: 202 million USD – speaker programmes with fees, luxury meals and travel USAGifts, hospitality and benefits €177.8m

Gilead paid physicians who spoke at or attended events on its HIV medicines fees, meals and travel expenses to promote prescriptions; high prescribers received hundreds of thousands of dollars, and events took place at luxury restaurants. The court-approved settlement of 202 million USD contains extensive admissions of fact.

What organisations can take from it

Selecting speakers by prescription volume turns continuing education into bribery – selection criteria and hospitality limits must be documented.

Relevance to training and awareness

Fees and hospitality at professional events

Authority / court
U.S. Attorney's Office, Southern District of New York; U.S. District Court (S.D.N.Y.)
Area of law
Bribery and corruption · Gifts, hospitality and benefits
Legal basis
Anti-Kickback Statute (42 U.S.C. § 1320a-7b(b)); False Claims Act (31 U.S.C. §§ 3729 ff.)
Action
Other
Status of proceedings
final
Sector
Chemicals and pharmaceuticals
Employees
10,000 or more
Published
29 Apr 2025

Original amount 202,000,000 USD, converted at the ECB reference rate of 28 Apr 2025.

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

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28 Apr 2025 Bayer S.A.Bayer pays 5 million BRL in CADE settlement over information exchange among employers BrazilCartels and collusion €773,398

Bayer S.A. concluded a settlement (Termo de Compromisso de Cessação) with the Conselho Administrativo de Defesa Econômica (CADE, Brazilian competition authority) in proceedings concerning the exchange of competitively sensitive information between employers in the consumer goods sector with possible effects on the Brazilian labour market. The company admitted its participation, undertook to cease the conduct and to cooperate with the investigation, and allegedly pays 5,003,188.80 BRL to the Fund for Diffuse Rights (FDD). In the same proceedings, 3M do Brasil concluded a separate settlement of allegedly 4,454,414.82 BRL. The amount and the facts have not been confirmed against the primary source.

What organisations can take from it

Exchanging sensitive HR and labour market information between competing employers also carries competition law risk.

Relevance to training and awareness

Competition law in HR: information exchange between employers

Authority / court
Conselho Administrativo de Defesa Econômica (CADE), Tribunal Administrativo
Area of law
Competition law · Cartels and collusion
Legal basis
Lei nº 12.529/2011 (Lei de Defesa da Concorrência), Termo de Compromisso de Cessação
Action
Other
Status of proceedings
final
Sector
Chemicals and pharmaceuticals
Employees
10,000 or more
Published
6 May 2025

Original amount 5,003,188.8 BRL, converted at the ECB reference rate of 28 Apr 2025.

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

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24 Apr 2025 Johnson & Johnson Consumer NV; Boehringer Ingelheim SComm; Haleon Belgium NVJohnson & Johnson, Boehringer, Haleon: 11.2 million EUR for shelf-placement collusion in pharmacies BelgiumCartels and collusion €11.2m

Over more than 15 years, the three OTC medicine manufacturers jointly developed the category management project ‘SMAN’, through which they steered the placement of non-prescription medicines in selected pharmacies in their favour and disadvantaged or excluded competing products. In a settlement procedure, the Autorité belge de la Concurrence / Belgische Mededingingsautoriteit (Belgian Competition Authority, BMA) imposed a total of 11,249,280.48 EUR.

What organisations can take from it

Category management agreements with retailers must not push competitors off the shelf – joint planograms with competitors are off limits.

Relevance to training and awareness

Competition law limits of category management

Authority / court
Autorité belge de la Concurrence / Belgische Mededingingsautoriteit (BMA)
Area of law
Competition law · Cartels and collusion
Legal basis
Code de droit économique Art. IV.1; AEUV Art. 101
Action
Fine
Status of proceedings
final
Sector
Chemicals and pharmaceuticals
Employees
10,000 or more
Published
24 Apr 2025

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

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10 Apr 2025 Boehringer Ingelheim, Alkaloids of Australia, C2 PHARMA u. a. (7 Unternehmen)WEKO sanctions active-ingredient cartel over butylscopolamine bromide at around CHF 600,000 SwitzerlandCartels and collusion €645,231

Between 2005 and 2019 Boehringer Ingelheim, Alkaloids of Australia, Alkaloids Corporation, Alchem, C2 PHARMA, Linnea and Transo-Pharm set minimum selling prices for the active ingredient butylscopolamine bromide (SNBB), allocated quotas and exchanged sensitive business information. The Wettbewerbskommission (WEKO, Swiss Competition Commission) closed the case with amicable settlements; sanctions total around CHF 600,000, with C2 PHARMA as the self-reporting party exempted in full and Transo-Pharm and Linnea in part. It is the first cartel concerning a pharmaceutical active ingredient that WEKO has sanctioned.

What organisations can take from it

Even small niche markets for intermediate products are watched by competition authorities, and the first to report can escape the sanction entirely.

Relevance to training and awareness

Cartel risks for intermediate products and active ingredients; leniency programme

Authority / court
Wettbewerbskommission (WEKO)
Area of law
Competition law · Cartels and collusion
Legal basis
Kartellgesetz (KG): Preis- und Mengenabrede, einvernehmliche Regelungen, Bonusregelung
Action
Fine
Status of proceedings
unknown
Sector
Chemicals and pharmaceuticals
Mitigating circumstances
Amicable settlements; full immunity for C2 PHARMA (leniency programme), partial reduction for Transo-Pharm and Linnea.
Published
10 Apr 2025

Original amount 600,000 CHF, converted at the ECB reference rate of 10 Apr 2025.

Checked against the official source on 2 Oct 2026 · Direct link

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8 Apr 2025 Pailpac (Pty) LtdAlleged abuse of dominance: Pailpac allegedly pays ZAR 5m and ends exclusive contracts South AfricaAbuse of market power €236,068

On 8 April 2025 the Competition Tribunal (South Africa's competition adjudicator) confirmed a settlement with Pailpac (Pty) Ltd, a maker of injection-moulded plastic pails for the paints and coatings industry. The Competition Commission (competition authority) alleged that, as the dominant supplier of containers for water-based coatings, the company had tied major customers through exclusive or near-exclusive supply agreements and used below-cost pricing; Pailpac disputes this. It nevertheless allegedly pays an administrative penalty of 5,000,000 ZAR, releases customers from exclusivity and automatic renewal clauses, will buy packaging waste from small businesses and informal waste collectors for five years and will introduce a compliance programme.

What organisations can take from it

Suppliers with strong market positions should have exclusivity and automatic renewal clauses checked under competition law before tying major customers to them.

Relevance to training and awareness

Exclusive contracts and below-cost pricing by dominant firms

Authority / court
Competition Tribunal of South Africa (auf Antrag der Competition Commission)
Area of law
Competition law · Abuse of market power
Legal basis
Section 8(1)(d)(i) und 8(1)(c) Competition Act 89 of 1998 (Vorwurf der Competition Commission, ohne Anerkenntnis)
Action
Fine
Status of proceedings
final
Sector
Chemicals and pharmaceuticals
Published
9 Apr 2025

Original amount 5,000,000 ZAR, converted at the ECB reference rate of 8 Apr 2025.

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

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18 Mar 2025 Ballance Agri-Nutrients LimitedBallance Agri-Nutrients: 420,000 NZD after a fatal conveyor belt accident New ZealandWorkplace safety and accidents €223,678

At the Mount Maunganui fertiliser plant in July 2023, a worker cleaning the conveyor system fell onto a moving belt, was dragged under the frame of another conveyor and died. There was no effective, trained and monitored safe system of work for cleaning and maintenance, and no effective guarding or emergency stop devices. On 18 March 2025 the Tauranga District Court imposed a fine of 420,000 NZD (starting point 700,000 NZD, 40% discounts) and made no reparation order because the family had already received 287,202.86 NZD (77,000 NZD directly from the company and 210,202.86 NZD from a group life insurance policy held by the company).

What organisations can take from it

Cleaning and maintenance on conveyors only with the system made safe, with guarding, a reachable emergency stop and a trained, supervised safe system of work.

Relevance to training and awareness

Safe cleaning and maintenance on conveyor belts

Missing or inadequate training played a role in the decision.

Authority / court
Tauranga District Court (Anklage: WorkSafe New Zealand)
Area of law
Health and safety and employment law · Workplace safety and accidents
Legal basis
Health and Safety at Work Act 2015, ss 36(1)(a), 48(1), 48(2)(c) ([2025] NZDC 5282)
Action
Fine
Status of proceedings
final
Sector
Chemicals and pharmaceuticals
Mitigating circumstances
Guilty plea, remorse, cooperation and reparation, with discounts totalling 40%; payments to the family totalling 287,202.86 NZD, of which 77,000 NZD was paid directly and 210,202.86 NZD came from the company's group life insurance policy.

Original amount 420,000 NZD, converted at the ECB reference rate of 18 Mar 2025.

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24 Jan 2025 Pfizer Inc. (für die Tochter Biohaven Pharmaceutical Holding Company Ltd.)Pfizer/Biohaven: USD 59.7m over speaker fees and lavish meals for doctors USAGifts, hospitality and benefits €57.1m

Pfizer pays USD 59,746,277 on behalf of its subsidiary Biohaven to resolve False Claims Act and Anti-Kickback Statute allegations relating to the period before the acquisition; about USD 50.2 million goes to the federal government and about USD 9.5 million to state Medicaid programmes. From March 2020 to September 2022 Biohaven allegedly gave selected doctors speaker fees and meals at expensive restaurants to encourage prescriptions of the migraine drug Nurtec ODT; some events were attended repeatedly by the same doctors or by spouses, relatives and practice colleagues with no educational need.

What organisations can take from it

In acquisitions, the target's speaker programmes and payments to doctors belong in due diligence – the liability passes to the buyer.

Relevance to training and awareness

Speaker programmes: selection of speakers, repeat attendance, hospitality

Authority / court
U.S. Department of Justice (Civil Division; USAO Western District of New York)
Area of law
Bribery and corruption · Gifts, hospitality and benefits
Legal basis
False Claims Act; Anti-Kickback Statute
Action
Other
Status of proceedings
final
Sector
Chemicals and pharmaceuticals
Employees
10,000 or more
Published
24 Jan 2025

Original amount 59,746,277 USD, converted at the ECB reference rate of 24 Jan 2025.

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

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20 Jan 2025 Pharnext SAPharnext: FDA setbacks disclosed late and glossed over FranceDisclosure and reporting obligations €500,000

The biotech company did not disclose as soon as possible the FDA's request for an additional study on PXT-3003 and the subsequent rejection of an SPA application, and disseminated misleading communications to shareholders. Sanction imposed on Pharnext: 500,000 EUR.

What organisations can take from it

Negative feedback from regulatory authorities is regularly inside information and must not be given a positive spin in letters to shareholders.

Authority / court
Autorité des marchés financiers (AMF), Commission des sanctions
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Art. 17 MAR; Art. 12 Abs. 1 lit. c und Art. 15 MAR
Action
Fine
Status of proceedings
under appeal
Sector
Chemicals and pharmaceuticals
Liability of senior managers
Measures against individuals are not reported here.
Sources

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

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14 Jan 2025 AFCO (Tochtergesellschaft der Zep Inc.)Zep subsidiary AFCO: $161,310 proposed after nitrogen dioxide release USAWorkplace safety and accidents €157,452

In July 2024, nitrogen dioxide above the exposure limit was released during chemical processing at the plant of Zep subsidiary AFCO in Chambersburg (Pennsylvania); twelve employees were examined in hospital and two were admitted. The U.S. Occupational Safety and Health Administration (OSHA) criticised the lack of an emergency action plan, deficient respiratory protection and hazard communication programmes and a delayed evacuation, and proposed $161,310 (including one repeat violation).

What organisations can take from it

In the event of a chemical release, a rehearsed emergency and evacuation plan determines how many employees come to harm.

Relevance to training and awareness

Responding to gas releases and evacuation

Authority / court
U.S. Department of Labor – Occupational Safety and Health Administration (OSHA)
Area of law
Health and safety and employment law · Workplace safety and accidents
Legal basis
29 CFR 1910.120, 1910.134, 1910.1200
Action
Fine
Status of proceedings
unknown
Sector
Chemicals and pharmaceuticals
Repeat case
yes
Published
14 Jan 2025

Original amount 161,310 USD, converted at the ECB reference rate of 14 Jan 2025.

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

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11 Dec 2024 Hipolabor Farmacêutica Ltda., Sanval Comércio e Indústria Ltda., Comercial Cirúrgica Rioclarense Ltda. u. a. (5 Unternehmen)CADE: hub-and-spoke cartel in medicines – BRL 45.3m on five companies BrazilCartels and collusion €7.15m

The CADE Tribunal convicted five companies of a cartel in public tenders for medicines and in private pharmaceutical sales which, according to CADE, operated at least from 2007 to 2011 in states including Minas Gerais, São Paulo, Bahia and Pernambuco; besides direct price-fixing between manufacturers, some manufacturers facilitated collusion between distributors (hub-and-spoke cartel). The fines on the companies total 45,328,574.05 BRL (Hipolabor Farmacêutica 15,741,025.02; Sanval 12,191,091.60; Comercial Cirúrgica Rioclarense 11,952,437.72; Rhamis Distribuidora Farmacêutica 3,585,615.18; Macromed 1,858,404.53 BRL). Proceedings against several other parties were closed for lack of evidence or because settlements had been fulfilled. The amount and the facts have not been confirmed against the primary source.

What organisations can take from it

Manufacturers must neither organise nor facilitate price coordination between their distributors; acting as the "hub" is itself a cartel infringement.

Relevance to training and awareness

Hub-and-spoke collusion between manufacturers and distributors in tenders

Authority / court
Conselho Administrativo de Defesa Econômica (CADE), Tribunal Administrativo
Area of law
Competition law · Cartels and collusion
Legal basis
Art. 20 I–IV i. V. m. Art. 21 I, II, III, VIII Lei nº 8.884/1994, entsprechend Art. 36 I–IV, § 3 I a, c, d Lei nº 12.529/2011; Bemessung nach Art. 37 Lei nº 12.529/2011
Action
Fine
Status of proceedings
unknown
Sector
Chemicals and pharmaceuticals
Liability of senior managers
Measures against individuals are not set out here.
Published
12 Dec 2024

Original amount 45,328,574.05 BRL, converted at the ECB reference rate of 11 Dec 2024.

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

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22 Nov 2024 Viatris Inc.Viatris: 1.5 million GBP – key staff replaced despite hold-separate order United KingdomMerger control €1.8m

During the review of the sale of the European rights to the hormone products Duphaston and Femoston to Theramex, an Initial Enforcement Order was in force. Viatris replaced members of the UK management without the consent of the Competition and Markets Authority (CMA) and subsequently failed to report the breach; the CMA imposed 1.5 million GBP.

What organisations can take from it

During a merger review, staffing decisions in the target business also require consent – and breaches must be reported immediately.

Relevance to training and awareness

Standstill and interim obligations in merger proceedings (management, HR)

Authority / court
Competition and Markets Authority (CMA)
Area of law
Competition law · Merger control
Legal basis
Enterprise Act 2002, s. 72(2) (Initial Enforcement Order), s. 94A
Action
Fine
Status of proceedings
unknown
Sector
Chemicals and pharmaceuticals
Employees
10,000 or more

Original amount 1,500,000 GBP, converted at the ECB reference rate of 22 Nov 2024.

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

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31 Oct 2024 Teva Pharmaceutical Industries (Teva-Gruppe)EU: 462.6 million EUR against Teva for patent misuse and disparaging a competing medicine EU levelAbuse of market power €462.6m

Teva abused its dominant position for the MS medicine Copaxone: it artificially extended patent protection by filing staggered divisional applications with the EPO and strategically withdrawing them, and spread misleading statements about an authorised competing product among physicians and decision-makers. Seven Member States were affected over periods of four to nine years.

What organisations can take from it

Communications by sales representatives and medical affairs about competing products must be substantiated and objective; patent strategies of dominant companies require competition law review.

Relevance to training and awareness

Disparaging statements about competing products to healthcare professionals

Authority / court
Europäische Kommission
Area of law
Competition law · Abuse of market power
Legal basis
Art. 102 AEUV
Action
Fine
Status of proceedings
unknown
Sector
Chemicals and pharmaceuticals
Employees
10,000 or more

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24 Jun 2024 a US flavours and fragrances manufacturer and its French subsidiaryFragrance manufacturer: €15.9m fine for deleting WhatsApp messages during an inspection EU levelCompetition lawanonymised €15.9m

During a European Commission inspection in the fragrance sector in March 2023, a senior employee of the manufacturer, after being informed of the inspection, deleted WhatsApp messages exchanged with a competitor on a mobile phone; the Commission treated this as obstruction of the inspection. It is the Commission's first fine for deleting messages in a messaging app; because of the manufacturer's cooperation, the amount was reduced by 50% to €15.9m (0.15% of total turnover).

What organisations can take from it

During regulatory inspections, companies must immediately ensure that nobody deletes data on work phones or in messaging apps.

Relevance to training and awareness

Conduct during dawn raids and preservation of evidence in messaging apps

Authority / court
Europäische Kommission
Area of law
Competition law
Legal basis
Verordnung (EG) Nr. 1/2003 (Behinderung einer Nachprüfung)
Action
Fine
Status of proceedings
unknown
Sector
Chemicals and pharmaceuticals
Culpability
intentional
Mitigating circumstances
Immediate acknowledgement, proactive cooperation and help in recovering the data: 50% reduction.
Liability of senior managers
The deletion was carried out by a senior employee; the fine is addressed to the companies.
Published
24 Jun 2024

Checked against the official source on 28 Sep 2026 · Company name anonymised since 24 Jun 2026 · Direct link

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19 Apr 2024 a Thai plastics companyThai plastics company pays 20 million USD for concealed sales of Iranian polyethylene USABreaches of sanctions and embargoesanonymised €18.8m

In 2017–2018, the Thai plastics company had US banks process 467 payments totalling 291 million USD for HDPE plastic produced in an Iranian joint venture with the Iranian state-owned petrochemical group. Shipping and documentation practices concealed the Iranian origin. The penalty was imposed by the US Treasury's Office of Foreign Assets Control (OFAC).

What organisations can take from it

Invoicing in US dollars brings US sanctions law into the business – holdings in embargoed countries require strict separation of payment flows.

Authority / court
U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC)
Area of law
Sanctions and export control · Breaches of sanctions and embargoes
Legal basis
Iranian Transactions and Sanctions Regulations (31 C.F.R. part 560)
Action
Fine
Status of proceedings
final
Sector
Chemicals and pharmaceuticals
Culpability
intentional
Published
19 Apr 2024

Original amount 20,000,000 USD, converted at the ECB reference rate of 19 Apr 2024.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 19 Apr 2026 · Direct link

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9 Jan 2024 a Brazilian pharmaceutical distributorBrazilian pharmaceutical distributor: CGU fine over false documents in vaccine contract BrazilBribery and corruptionanonymised €483,622

The Controladoria-Geral da União (CGU, Office of the Comptroller General) imposed on a pharmaceutical distributor, which now trades under a different name, a fine of BRL 3,879,251.35, extraordinary publication of the decision and a declaration of unsuitability for public contracts (declaração de inidoneidade). According to the final report, in the Ministry of Health's planned purchase of 20 million doses of a Covid-19 vaccine the company submitted a document that the vaccine manufacturer later described as false, as well as pro forma invoices that did not match the contract terms. On a request for reconsideration (pedido de reconsideração) the CGU reduced the fine to BRL 2,586,167.56 on 5 May 2025 and shortened the posting period for the publication from 75 to 60 days; the declaration of unsuitability remained in place.

What organisations can take from it

Anyone contracting with the state as the representative of a foreign manufacturer must check powers of attorney and invoices carefully; false documents lead to fines and debarment.

Relevance to training and awareness

Authenticity of proof of representation and invoices in public contracts

Authority / court
Controladoria-Geral da União (CGU)
Area of law
Bribery and corruption
Legal basis
Lei nº 12.846/2013, Art. 5 IV b und d, Art. 6; Lei nº 8.666/1993, Art. 87 IV und Art. 88 III
Action
Fine
Status of proceedings
reduced
Sector
Chemicals and pharmaceuticals
Mitigating circumstances
Following the request for reconsideration, the CGU reduced the fine from BRL 3,879,251.35 to BRL 2,586,167.56.
Published
15 Jan 2024

Original amount 2,586,167.56 BRL, converted at the ECB reference rate of 9 Jan 2024.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 9 Jan 2026 · Direct link

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20 Dec 2023 a Portuguese supplier of food supplements and health productsPortugal: €1.04m for health products supplier over imposed resale prices PortugalCartels and collusionanonymised €1.04m

The competition authority fined the supplier of food supplements and health products 1,040,000 EUR because between 2016 and 2022 it prescribed retail prices and discount limits to distributors, monitored them and responded to deviations with cuts in terms or supply restrictions. The decision is not final.

What organisations can take from it

Suppliers should rule out price instructions to distributors and their monitoring, both in contracts and in practice.

Relevance to training and awareness

Resale price maintenance

Authority / court
Autoridade da Concorrência (AdC)
Area of law
Competition law · Cartels and collusion
Legal basis
Art. 9 Lei n.º 19/2012 (Lei da Concorrência); Art. 101 AEUV
Action
Fine
Status of proceedings
under appeal
Sector
Chemicals and pharmaceuticals
Published
29 Dec 2023

Checked against the official source on 28 Sep 2026 · Company name anonymised since 20 Dec 2025 · Direct link

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19 Oct 2023 six manufacturers and traders of an active pharmaceutical ingredientEU: 13.4 million EUR against pharmaceutical ingredient cartel (SNBB) EU levelCartels and collusionanonymised €13.4m

From 2005 to 2019, six manufacturers and traders of the active ingredient SNBB (the base substance for a branded medicine and generics) fixed minimum prices, allocated quotas and exchanged sensitive information. This was the first cartel concerning an active pharmaceutical ingredient that the Commission has sanctioned; the leniency applicant received full immunity, and all parties reached a settlement.

What organisations can take from it

Even small niche markets for active ingredients are in the spotlight – contacts with competitors about prices or volumes are off-limits.

Relevance to training and awareness

Price and quota agreements in the trade in active ingredients

Authority / court
Europäische Kommission
Area of law
Competition law · Cartels and collusion
Legal basis
Art. 101 AEUV, Art. 53 EWR-Abkommen
Action
Fine
Status of proceedings
unknown
Sector
Chemicals and pharmaceuticals
Mitigating circumstances
Leniency programme (leniency applicant 100 %, a second company 50 %, a third 30 %), 10 % settlement reduction

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 19 Oct 2025 · Direct link

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8 Sep 2023 a US cleantech companySEC: US cleantech firm pays 225,000 US dollars over award waivers USARetaliation against whistleblowersanonymised €210,202

From February 2020 to March 2023, the unlisted cleantech company (around 236 employees) had 22 departing employees waive awards for reports to authorities. After contact by the U.S. Securities and Exchange Commission (SEC), the company amended the agreements and informed those affected; the penalty amounted to 225,000 US dollars.

What organisations can take from it

Unlisted companies are also subject to the SEC's whistleblower protection rules.

Relevance to training and awareness

Whistleblower protection in contract templates (HR/Legal)

Authority / court
U.S. Securities and Exchange Commission
Area of law
Whistleblower protection · Retaliation against whistleblowers
Legal basis
Securities Exchange Act of 1934, Rule 21F-17(a)
Action
Fine
Status of proceedings
final
Sector
Chemicals and pharmaceuticals
Employees
50 to 249
Mitigating circumstances
Revision of the separation agreements and information provided to the former employees affected
Published
8 Sep 2023

Original amount 225,000 USD, converted at the ECB reference rate of 8 Sep 2023.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 8 Sep 2025 · Direct link

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21 Aug 2023 a US generic drug manufacturerDOJ: generics manufacturer pays 225 million USD criminal penalty over generic drug price fixing USACartels and collusionanonymised €206.3m

In a Deferred Prosecution Agreement, the manufacturer admitted to three conspiracies involving price fixing, customer allocation and bid rigging for generic drugs (including pravastatin). The manufacturer is paying a criminal penalty of 225 million USD in instalments, donating medicines worth 50 million USD and must divest its pravastatin business under the supervision of a monitor.

What organisations can take from it

In addition to penalties running into millions, antitrust violations can force companies to divest entire product lines.

Relevance to training and awareness

Agreements among generic drug manufacturers on prices and customers

Authority / court
U.S. Department of Justice, Antitrust Division
Area of law
Competition law · Cartels and collusion
Legal basis
15 U.S.C. § 1 (Sherman Act)
Action
Fine
Status of proceedings
unknown
Sector
Chemicals and pharmaceuticals
Employees
10,000 or more

Original amount 225,000,000 USD, converted at the ECB reference rate of 21 Aug 2023.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 21 Aug 2025 · Direct link

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28 Jul 2023 a Hungarian pharmaceutical companyPharmaceutical company: 37 million HUF fine over doctors' fees and excess hospitality HungaryGifts, hospitality and benefitsanonymised €96,540

The Országos Gyógyszerészeti és Élelmezés-egészségügyi Intézet (OGYÉI, Hungarian National Institute of Pharmacy and Nutrition) fined a Hungarian pharmaceutical company 37,000,000 HUF and prohibited continuation of the infringements, because the company had in numerous cases granted prescribing doctors unlawful financial benefits through fee contracts – for example for role-plays used to train its own sales representatives, specialist articles for a company-branded promotional publication, promotional lectures, and paid lectures given by heads of department to their own staff. In addition, hospitality exceeded the statutory per-head limit in four cases at its own professional events, support enabling doctors to attend two international professional events was not reported, and there were shortcomings concerning warning symbols in promotional material, the handing out of samples and donation records. The decision was issued in new proceedings after the Fővárosi Törvényszék (Budapest-Capital Regional Court) had annulled an earlier 2020 decision for inadequate reasoning on the amount of the sanction, while upholding the legal assessment of the fee contracts.

What organisations can take from it

Fee contracts with prescribing doctors need a genuine professional service, separate from sales promotion and paid at a fair rate – otherwise they count as a prohibited benefit.

Relevance to training and awareness

Fee contracts, lectures and hospitality for doctors in pharmaceutical marketing

Authority / court
Országos Gyógyszerészeti és Élelmezés-egészségügyi Intézet (OGYÉI; Rechtsnachfolger NNGYK)
Area of law
Bribery and corruption · Gifts, hospitality and benefits
Legal basis
Gyftv. (Gesetz Nr. XCVIII/2006) § 14 Abs. 1, 2 und 10, § 11/B Abs. 2, § 19 Abs. 2 lit. c und d; EüM-Verordnung 3/2009 § 7 Abs. 1 lit. a, § 10 Abs. 3
Action
Fine
Status of proceedings
final
Sector
Chemicals and pharmaceuticals
Published
28 Jul 2023

Original amount 37,000,000 HUF, converted at the ECB reference rate of 28 Jul 2023.

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

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11 Apr 2023 a Japanese pharmaceutical manufacturerDrug maker: surcharge for unsubstantiated virus-removal claims for chlorine dioxide products JapanMisleading advertising and pricinganonymised €4.18m

From September 2018 to April 2022, the pharmaceutical manufacturer claimed on packaging, its own website, on television and in adverts on a video platform that products of its brand (room dispensers, clip-on sticks, sprays) remove airborne viruses and bacteria from indoor air by means of chlorine dioxide. The documents submitted did not substantiate this effect and the disclaimers on the packaging did not change the overall impression; the surcharge of 607,440,000 JPY is made up of individual amounts for five product groups, including 452,200,000 JPY for the room dispensers.

What organisations can take from it

Hygiene claims need evidence for the advertised conditions of use; a reference to tests in a closed space does not rescue a sweeping advertising claim.

Relevance to training and awareness

Substantiating efficacy and health claims in advertising

Authority / court
Consumer Affairs Agency (消費者庁, CAA)
Area of law
Consumer protection and online retail · Misleading advertising and pricing
Legal basis
Art. 8 Abs. 1 und 3 i. V. m. Art. 5 Nr. 1 Act against Unjustifiable Premiums and Misleading Representations (不当景品類及び不当表示防止法, Gesetz Nr. 134/1962)
Action
Fine
Status of proceedings
unknown
Sector
Chemicals and pharmaceuticals
Culpability
negligent
Published
11 Apr 2023

Original amount 607,440,000 JPY, converted at the ECB reference rate of 11 Apr 2023.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 11 Apr 2025 · Direct link

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24 Mar 2023 a listed Bulgarian fertiliser producerFertiliser producer: BGN 35,000 for misleading statement on production halt BulgariaMarket abuse and insider dealinganonymised €17,895

On 1 August 2022 the listed fertiliser producer announced on its website that it had stopped production for a scheduled annual overhaul, but concealed the actual reason, natural gas prices it could not bear; the KFN (Komisia za finansov nadzor, Bulgarian Financial Supervision Commission) regarded this as giving misleading signals about the share price. Sanctioning act Р-14-9 of 24 March 2023 set BGN 35,000 for this; two further acts of the same day set BGN 3,500 for the delayed disclosure of the inside information and BGN 1,400 for failing to publish transactions notified under Art. 19 MAR.

What organisations can take from it

A corporate announcement giving a sugar-coated reason for a production halt can itself amount to market manipulation.

Relevance to training and awareness

Ad hoc communication: state the real reasons and disclose inside information on time

Authority / court
Комисия за финансов надзор (КФН, Bulgarische Finanzaufsichtskommission)
Area of law
Capital markets and financial supervision · Market abuse and insider dealing
Legal basis
Art. 15 i. V. m. Art. 12 Abs. 1 lit. c Verordnung (EU) Nr. 596/2014 (MAR)
Action
Fine
Status of proceedings
final
Sector
Chemicals and pharmaceuticals
Culpability
intentional

Original amount 35,000 BGN, converted at the ECB reference rate of 24 Mar 2023.

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Checked against the official source on 28 Sep 2026 · Company name anonymised since 24 Mar 2025 · Direct link

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16 Jan 2023 a British paint manufacturerPaint manufacturer: 650,000 GBP fine after TBT entered protected estuary United KingdomWaste and hazardous substancesanonymised €895,685

In 2015/2016, sediments containing the banned antifouling agent tributyltin (TBT) as well as copper, mercury and arsenic escaped from a tank at the company's paint testing facility into a protected estuary; one sample exceeded the safe TBT level by a factor of 80,000. The subsidiary of a paint group was fined 650,000 GBP and ordered to pay 144,992 GBP in costs; it had denied the charges to the end.

What organisations can take from it

Legacy sites with hazardous substances need sealed containment systems, and waste obligations also apply to residues from testing facilities.

Authority / court
Plymouth Crown Court (Anklage: Environment Agency)
Area of law
Environment and sustainability · Waste and hazardous substances
Legal basis
Regulations 12(1)(b) und 38(1) Environmental Permitting (England and Wales) Regulations 2010; Sections 34(1)(b) und 34(6) Environmental Protection Act 1990
Action
Fine
Status of proceedings
unknown
Sector
Chemicals and pharmaceuticals
Employees
250 to 999
Published
16 Jan 2023

Original amount 794,992 GBP, converted at the ECB reference rate of 16 Jan 2023.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 16 Jan 2025 · Direct link

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19 Dec 2022 a US chemical and technology companyUS chemical company: BRL 638m leniency agreement over bribery in state-owned group contracts BrazilBribery of public officialsanonymised €113.3m

A US chemical and technology company undertook, in a leniency agreement with the Controladoria-Geral da União (CGU, Office of the Comptroller General) and the Advocacia-Geral da União (AGU, Office of the Attorney General), to pay BRL 638,046,365.87 (equivalent to USD 120,828,384.25) because, in connection with contracts with a state-controlled oil company, it had made improper payments for the benefit of public officials through intermediary companies. According to the annexes, USD 75,817,531.39 relates to disgorgement of profit and USD 10,601,873.74 to presumed damage (bribes) in favour of the oil company, while USD 5,708,217.91 is the fine under the Anti-Corruption Act (Lei 12.846/2013) and USD 28,700,761.19 the fine under the Administrative Improbity Act (Lei 8.429/1992). According to its own statement, the company concluded agreements with the Federal Public Prosecutor's Office (MPF), the US Department of Justice and the SEC on the same day.

What organisations can take from it

Payments to officials of state-owned clients routed through intermediary companies lead to disgorgement and fines under several legal bases at once.

Relevance to training and awareness

Bribery through intermediary companies in contracts with a state-owned enterprise

Authority / court
Controladoria-Geral da União (CGU) und Advocacia-Geral da União (AGU)
Area of law
Bribery and corruption · Bribery of public officials
Legal basis
Lei 12.846/2013, Arts. 16 und 17; Lei 8.429/1992; Decreto 11.129/2022, Art. 33
Action
Disgorgement of profits
Status of proceedings
final
Sector
Chemicals and pharmaceuticals
Mitigating circumstances
Credit was given for remediation of damage (1%), cooperation (1%), voluntary admission (2%) and an applied compliance programme (3.06%).
Liability of senior managers
The fine calculation treated tolerance or knowledge by senior management as an aggravating factor at the maximum rate of 3%.

Original amount 638,046,365.87 BRL, converted at the ECB reference rate of 19 Dec 2022.

Checked against the official source on 7 Oct 2026 · Company name anonymised since 19 Dec 2024 · Direct link

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29 Nov 2022 six purchasers of styrene monomerEU: 157 million EUR against purchasing cartel for styrene monomer EU levelCartels and collusionanonymised €157.1m

From 2012 to 2018, six purchasers of styrene coordinated their negotiating strategy for the industry reference price (SMCP) and exchanged price information in order to push down the purchase price. The Commission imposed fines totalling 157 million EUR, including 32.505 million EUR on one company and 31.72 million EUR on another; the leniency applicant escaped a fine.

What organisations can take from it

Not only selling but also purchasing agreements are prohibited – buyers need competition law training just as much as sales staff.

Relevance to training and awareness

Purchasing cartel: coordination of negotiating strategies among buyers

Authority / court
Europäische Kommission
Area of law
Competition law · Cartels and collusion
Legal basis
Art. 101 AEUV, Art. 53 EWR-Abkommen
Action
Fine
Status of proceedings
unknown
Sector
Chemicals and pharmaceuticals
Mitigating circumstances
Leniency programme for almost all parties, 10 % settlement reduction

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 29 Nov 2024 · Direct link

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15 Nov 2022 a Portuguese food supplement supplierPortugal: €1.26m for food supplement supplier over resale price maintenance PortugalCartels and collusionanonymised €1.26m

The competition authority fined the food supplement supplier 1,258,900 EUR because, from October 2015 to January 2022, it dictated retail prices and maximum discounts to distributors, monitored compliance and punished deviations with worse terms or supply cuts. The fine was reduced by 30% in the settlement procedure.

What organisations can take from it

Recommended prices become prohibited resale price maintenance once compliance is monitored and deviations are punished.

Relevance to training and awareness

Resale price maintenance

Authority / court
Autoridade da Concorrência (AdC)
Area of law
Competition law · Cartels and collusion
Legal basis
Art. 9 Lei n.º 19/2012 (Lei da Concorrência); Art. 101 AEUV
Action
Fine
Status of proceedings
unknown
Sector
Chemicals and pharmaceuticals
Mitigating circumstances
Settlement procedure (transação), practice ended; 30% reduction.
Published
19 Dec 2022

Checked against the official source on 28 Sep 2026 · Company name anonymised since 15 Nov 2024 · Direct link

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10 Nov 2022 three companies of an international pharmaceutical groupCNMC: €10.25m fine on pharmaceutical group for excessive pricing of an orphan medicine SpainAbuse of market poweranonymised €10.3m

The Comisión Nacional de los Mercados y la Competencia (CNMC, Spanish competition and markets authority) imposed a fine of 10,250,000 EUR, for which three companies of the pharmaceutical group are jointly and severally liable, because as the sole supplier of CDCA medicines for the rare metabolic disease cerebrotendinous xanthomatosis they abused their dominant position and charged the Spanish national health system an excessive price. In addition, the group must waive the exclusivity agreed with the only supplier of the active ingredient and market the product directly in Spain.

What organisations can take from it

A sole supplier of an indispensable medicine must be able to justify price increases objectively and must not cut competitors off from the active ingredient through exclusive supply agreements.

Relevance to training and awareness

Pricing by dominant undertakings (excessive prices)

Authority / court
Comisión Nacional de los Mercados y la Competencia (CNMC)
Area of law
Competition law · Abuse of market power
Legal basis
Art. 2 Ley 15/2007 de Defensa de la Competencia; Art. 102 AEUV
Action
Fine
Status of proceedings
unknown
Sector
Chemicals and pharmaceuticals
Published
14 Nov 2022

Checked against the official source on 28 Sep 2026 · Company name anonymised since 10 Nov 2024 · Direct link

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24 Oct 2022 a Canadian cannabis producerCannabis producer: CAD 1.3 million over defective interim financial statements and weak controls Canada, OntarioDisclosure and reporting obligationsanonymised €962,820

The Capital Markets Tribunal approved a settlement in which the cannabis producer admitted that interim financial statements had not been prepared in accordance with applicable accounting principles: in 2019 about CAD 7.6 million of revenue was recognised on wholesale transactions lacking commercial substance, and in the second quarter of 2021 an impairment of USD 234.9 million on goodwill and intangible assets was missing. The producer pays an administrative penalty of CAD 1,300,000 and investigation costs of CAD 40,000 (CAD 1,340,000 in total) and must have its internal control over financial reporting reviewed by an independent consultant and implement the consultant's recommendations.

What organisations can take from it

Non-routine transactions and impairment tests need effective controls; otherwise restatements and sanctions by the securities regulator follow.

Relevance to training and awareness

Internal control over financial reporting and revenue recognition

Missing or inadequate training played a role in the decision.

Authority / court
Capital Markets Tribunal (Ontario) auf Antrag der Ontario Securities Commission
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Securities Act (Ontario), RSO 1990, c S.5, s. 77 (Zwischenabschlüsse nach GAAP); Anordnungen nach s. 127(1) und s. 127.1
Action
Fine
Status of proceedings
final
Sector
Chemicals and pharmaceuticals
Mitigating circumstances
The company uncovered the errors itself following internal complaints from employees, reported them to the Commission before its internal investigation was complete, cooperated fully, restated the financial statements and improved its controls, training and accounting staffing.
Published
24 Oct 2022

Original amount 1,300,000 CAD, converted at the ECB reference rate of 24 Oct 2022.

Checked against the official source on 3 Oct 2026 · Company name anonymised since 24 Oct 2024 · Direct link

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13 Oct 2022 five pharmaceutical companiesPay-for-delay in cancer drugs: KFTC sanctions originator and generic manufacturers South KoreaCartels and collusionanonymised €1.9m

The Korea Fair Trade Commission (KFTC, Korea's competition authority) objected to an agreement concluded at the end of September 2016 under which the generics side undertook not to manufacture or launch generic versions of three cancer drugs in Korea from October 2016 to December 2020, receiving in return exclusive distribution rights for these originator products from the originator side; according to the KFTC, the arrangement was terminated early on 12 January 2018. It issued cease-and-desist orders against all five companies (two on the originator side, including its Korean company, and three on the generics side, including its Korean company) and provisionally set fines totalling KRW 2,645 million: KRW 1,146 million for the originator side and KRW 1,499 million for the generics side.

What organisations can take from it

Distribution or licensing agreements with a potential generic manufacturer must not contain a clause that rules out its own market entry.

Relevance to training and awareness

Agreements with potential competitors to refrain from market entry (pay-for-delay)

Authority / court
Korea Fair Trade Commission (KFTC)
Area of law
Competition law · Cartels and collusion
Legal basis
Art. 19 Abs. 1 Nr. 3 MRFTA a. F. (Monopoly Regulation and Fair Trade Act; heute Art. 40 Abs. 1 Nr. 3)
Action
Fine
Status of proceedings
unknown
Sector
Chemicals and pharmaceuticals
Published
13 Oct 2022

Original amount 2,645,000,000 KRW, converted at the ECB reference rate of 13 Oct 2022.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 13 Oct 2024 · Direct link

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