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.
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Where?
by authority- Controladoria-Geral da União (CGU) und Advocacia-Geral da União (AGU) 2 cases 50 % · €87.7m
- Conselho Administrativo de Defesa Econômica (CADE), Tribunal Administrativo 1 case 25 % · €2.63m
- Ministério do Trabalho e Emprego (MTE), Inspeção do Trabalho 1 case 25 % ·
What for?
by area of lawAll areas of law
Who?
by companyWhen?
per quarter, by date of decision| Period | Cases | Total |
|---|---|---|
| Q4 2023 | 0 | – |
| Q1 2024 | 0 | – |
| Q2 2024 | 0 | – |
| Q3 2024 | 0 | – |
| Q4 2024 | 1 | €17.8m |
| Q1 2025 | 1 | €69.9m |
| Q2 2025 | 0 | – |
| Q3 2025 | 1 | – |
| Q4 2025 | 0 | – |
| Q1 2026 | 0 | – |
| Q2 2026 | 1 | €2.63m |
| Q3 2026 | 0 | – |
| Q4 2026 | 0 | – |
4 cases
13 May 2026 Comércio de Combustíveis Stang Ltda., Pato Comércio de Combustíveis Ltda. u. a. (3 Unternehmen)CADE: fuel cartel in Coronel Vivida – fines cut to BRL 15.1m on embargos €2.63m
The CADE Tribunal convicted three petrol station companies because in 2017 they had divided the lots of municipal fuel tenders in Coronel Vivida (Paraná) among themselves in advance and had also coordinated retail pump prices. The fines on the companies initially totalled 43,953,905.42 BRL (Comércio de Combustíveis Stang 25,801,726.15; a further petrol station company 9,406,784.68; Pato Comércio de Combustíveis 8,745,394.59 BRL). On motions for clarification (embargos) the Tribunal reduced, on 1 July 2026, the fines on Stang to 4,615,849.76 BRL and on Pato to 1,090,682.28 BRL owing to a subsequently arising fact relevant to the calculation, leaving 15,113,316.72 BRL. The amount and the facts have not been confirmed against the primary source.
Dividing lots in public tenders is a cartel infringement carrying heavy fines, even in small municipal procurement.
Division of tender lots between competitors
- 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; Art. 38 VI (Handelsverbot für natürliche Personen)
- Action
- Fine
- Status of proceedings
- reduced
- Sector
- Energy and utilities
- Liability of senior managers
- Measures against individuals are not set out here.
- Published
- 13 May 2026
Original amount 15,113,316.72 BRL, converted at the ECB reference rate of 13 May 2026.
- Diário Oficial da União, 22.05.2026, Seção 1, S. 54: Ata da 265ª Sessão Ordinária de Julgamento (13.05.2026), PA nº 08700.002545/2023-70 Official register or notice
- Diário Oficial da União, 08.07.2026, Seção 1, S. 132: Ata da 268ª Sessão Ordinária de Julgamento (01.07.2026), Embargos – Herabsetzung Official register or notice
- CADE, 13.05.2026: Cade condena empresas e empresários por cartel de combustíveis em Coronel Vivida/PR Press release of an authority
Checked against the official source on 3 Oct 2026 · Direct link
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8 Sep 2025 Centroálcool S/A (em recuperação judicial)Centroálcool: again on the ‘Lista Suja’ – 58 workers in conditions akin to slavery Other
The Ministry of Labour and Employment (MTE) again entered Centroálcool S/A (em recuperação judicial) on 6 April 2026 in the register of employers that have kept workers in conditions akin to slavery (the ‘Lista Suja’). The entry is based on a labour inspection in 2025 involving 58 affected workers and the administrative finding of 8 September 2025. The company is already on the list with two entries from a 2023 inspection in Inhumas (GO) (53 and 5 workers, finding of 28 February 2024).
After a first finding, working conditions must be checked systematically at all sites, otherwise the next entry follows.
Conditions akin to slavery in alcohol production
- Authority / court
- Ministério do Trabalho e Emprego (MTE), Inspeção do Trabalho
- Area of law
- Supply chain and human rights · Forced and child labour
- Legal basis
- Portaria Interministerial MTE/MDHC/MIR nº 18/2024, Art. 2
- Action
- Other
- Status of proceedings
- unknown
- Sector
- Energy and utilities
- Repeat case
- yes
- Published
- 6 Apr 2026
Checked against the official source on 3 Oct 2026 · Direct link
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28 Mar 2025 Trafigura Beheer B.V.Trafigura Beheer: leniency agreement with CGU and AGU for BRL 435.4m €69.9m
Trafigura Beheer B.V. entered into 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) in which it admitted paying undue advantages to public officials and using front persons to conceal its interests. It allegedly pays BRL 435,410,672.26: BRL 153,710,689.11 within ten days (the conversion of USD 26,829,346; under its agreement with the US Department of Justice on a fine of USD 80,488,040, this part of the US fine may be offset by the payment to the Brazilian authorities) and BRL 281,699,983.15 (the conversion of USD 49,169,165.53) as the remaining balance. The amount and the facts have not been confirmed against the primary source.
In corruption cases involving several countries, double payments can be avoided through coordinated agreements with all the authorities involved.
Payments to public officials and use of 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 nº 12.846/2013, Art. 5 I und III, Art. 16; Lei nº 8.429/1992; Decreto nº 11.129/2022
- Action
- Fine
- Status of proceedings
- final
- Sector
- Energy and utilities
- Mitigating circumstances
- Coordination with the US proceedings so that part of the Brazilian payment can be credited against the US fine; obligation to improve the integrity programme under CGU monitoring for 36 months.
Original amount 435,410,672.26 BRL, converted at the ECB reference rate of 28 Mar 2025.
- Acordo de Leniência CGU/AGU – Trafigura Beheer B.V. (Processo 00190.100002/2022-21, SEI 3569333) Decision of an authority
- CGU: Acordos de leniência celebrados (Liste mit Unternehmen und Beträgen) Official register or notice
Checked against the official source on 3 Oct 2026 · Direct link
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14 Nov 2024 Freepoint Commodities LLCFreepoint Commodities: leniency agreement worth BRL 131.25m over bribery €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.
Companies that win business through intermediaries must control their payments to officials – otherwise the company itself is liable.
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.
- CGU/AGU – Acordo de Leniência com a Freepoint Commodities LLC (Processo 00190.104910/2023-75) Decision of an authority
- Acordo de Leniência Freepoint – Anexo II: Demonstrativo de cálculo e valor da multa Decision of an authority
- Acordo de Leniência Freepoint – Anexo III: Demonstrativo do valor da dívida, destinação e pagamento Decision of an authority
- CGU – Acordos de leniência celebrados (Liste) Official register or notice
Checked against the official source on 3 Oct 2026 · Direct link