Compliance Radar

Who was sanctioned, and for what?

Fines, court rulings and incidents from Europe, North America, Latin America, Asia-Pacific and Middle East: 1,929 cases from 40 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.

1case from 1 jurisdiction
€17.8mTotal of monetary amounts
€17.8mLargest single case: Freepoint Commodities LLC
€17.8mMedian per case with an amount

Click a bar to drill down one level.

When?

per quarter, by date of decision
Trend
PeriodCasesTotal
Q4 20230–
Q1 20240–
Q2 20240–
Q3 20240–
Q4 20241€17.8m
Q1 20250–
Q2 20250–
Q3 20250–
Q4 20250–
Q1 20260–
Q2 20260–
Q3 20260–
Q4 20260–

1 case

14 Nov 2024 Freepoint Commodities LLCFreepoint Commodities: leniency agreement worth BRL 131.25m over bribery BrazilBribery of public officials €17.8m

The US company Freepoint Commodities LLC admitted, in a leniency agreement with the CGU and the AGU, to having paid undue advantages to public officials through intermediaries (Art. 5 I and III Lei 12.846/2013) and allegedly pays BRL 108,710,739.68 as a fine plus disgorgement. According to Annex III, BRL 60,919,037.14 is the fine payable to the Union (after a 67% reduction) and BRL 47,791,702.54 is disgorgement. Damages to Petrobras of BRL 22,542,907.62 are set out only in the text. The agreement also stated a total of BRL 131,253,647.32 (USD 22,744,839.85); the two centavos by which that total exceeds the fine, the disgorgement and the damages are not smoothed. If the company resumes business in Brazil within five years, it must adapt its compliance programme to Brazilian law and report to the CGU. The amount and the facts have not been confirmed against the primary source.

What organisations can take from it

Companies that win business through intermediaries must control their payments to officials – otherwise the company itself is liable.

Relevance to training and awareness

Bribery of public officials through intermediaries

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, Art. 5 I und III, Art. 6 I, Arts. 16, 17 und 19 I; Lei 8.429/1992; Decreto 11.129/2022
Action
Fine
Status of proceedings
final
Sector
Energy and utilities
Mitigating circumstances
Credit was given for remediation of damage (1%), cooperation (1.5%) and voluntary admission (2%); no reduction was granted for a compliance programme.
Liability of senior managers
Tolerance or knowledge by management was applied as an aggravating factor at 2.5%.

Original amount 108,710,739.68 BRL, converted at the ECB reference rate of 14 Nov 2024.

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

Report an error

Anonymous: we store only your text, no contact details and no IP address.

Ready for training that actually lands?

Try the combination for free: automated administration for you, learning formats that fit your team, with no minimum or credit card.

Start 14-day free trial