Who was sanctioned, and for what?

From November 2023 to June 2025, the Indian conglomerate bought allegedly Omani and Iraqi liquefied petroleum gas (LPG) via a trader in Dubai which in fact originated from Iran; 32 payments totalling around 192 million USD were routed through US banks. The US Treasury's Office of Foreign Assets Control (OFAC) assessed the violations as egregious and not voluntarily self-disclosed; Adani had recklessly ignored numerous warning signs (AIS manipulation by the tankers, implausible loading ports, conspicuous price discounts, irregularities in the certificates of origin).

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); IEEPA

Action

Fine

Status of proceedings

final

Sector

Energy and utilities

Mitigating circumstances

Remedial measures after discovery and cooperation with OFAC

Published

18 May 2026

Original amount 275,000,000 USD, converted at the ECB reference rate of 18 May 2026.

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

Under a consent decree with the EPA, the US Department of Justice and the New Mexico Environment Department, HF Sinclair Navajo Refining will allegedly pay a total of 35,000,000 USD for its refinery in Artesia (New Mexico): a civil penalty of 33,916,450 USD for excess emissions of, among others, benzene, volatile organic compounds, nitrogen oxides and sulphur dioxide, and 1,083,550 USD for breaches of a 2002 settlement; the civil penalty is split between the federal government and New Mexico. In addition, measures estimated at USD 137m are required, including real-time air monitors at the fenceline and in the town with publicly available results, and a flare gas recovery system. The authority allegedly made the findings set out here; this account is not based on a final judgment. The decision is not final.

Authority / court

U.S. Environmental Protection Agency (EPA) / U.S. Department of Justice mit New Mexico Environment Department (U.S. District Court, District of New Mexico)

Area of law

Environment and sustainability · Emissions and permits

Legal basis

Clean Air Act (NESHAP für Erdölraffinerien und Benzolabfälle, NSPS, Title-V-Genehmigung); New Mexico Air Quality Control Act; Consent Decree von 2002

Action

Fine

Status of proceedings

unknown

Sector

Energy and utilities

Repeat case

yes

Published

17 Jan 2025

Original amount 35,000,000 USD, converted at the ECB reference rate of 17 Jan 2025.

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

The U.S. Forced Labor Enforcement Task Force (FLETF) added the manufacturer of silicon ingots, wafers and solar modules from Jiangsu Province to the Uyghur Forced Labor Prevention Act (UFLPA) Entity List because it sources material from 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.

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

Energy and utilities

Published

15 Jan 2025

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

During the HSR waiting period for the 1.4 billion USD acquisition of EP Energy, XCL and Verdun already took control of day-to-day operations: they halted drilling projects, managed customer contracts in Utah and coordinated prices in Texas (94 days). In a settlement filed by the DOJ on behalf of the FTC, the companies agreed to a civil penalty of 5.6 million USD – the highest ever for gun-jumping in the US; court approval under the Tunney Act was still pending at the time of publication.

Authority / court

Federal Trade Commission (Klage durch das U.S. Department of Justice)

Area of law

Competition law · Merger control

Legal basis

Hart-Scott-Rodino Act

Action

Fine

Status of proceedings

unknown

Sector

Energy and utilities

Published

7 Jan 2025

Original amount 5,600,000 USD, converted at the ECB reference rate of 7 Jan 2025.

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

The U.S. Environmental Protection Agency (EPA, Region 10) imposed a civil penalty of 8,770 USD by consent agreement and final order on the City of Boardman (Oregon), whose drinking water system serves around 4,490 people. According to the EPA, the city had not prepared the risk and resilience assessment and emergency response plan required by the Safe Drinking Water Act on time and had not complied with a 2022 EPA order: at an inspection in April 2024 the assessment was an empty template, and the emergency response plan dated from 2005 and contained no cybersecurity section. The city admitted jurisdiction without admitting or denying the factual allegations and waived its right to appeal. The authority allegedly made the findings set out here; this account is not based on a final judgment.

Authority / court

U.S. Environmental Protection Agency (EPA), Region 10

Area of law

Information security and cyber · Critical infrastructure

Legal basis

Safe Drinking Water Act Section 1433(a) und (b) (42 U.S.C. § 300i-2) sowie Section 1414(g)(3)(A); Strafe nach Section 1414(g)(3)(B) (42 U.S.C. § 300g-3(g)(3)(B))

Action

Fine

Status of proceedings

final

Sector

Energy and utilities

Repeat case

yes

Published

7 Jan 2025

Original amount 8,770 USD, converted at the ECB reference rate of 7 Jan 2025.

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

The trading company sold physical gasoline below the bids in order to depress the benchmark price and thereby benefit its short positions in EBOB-related futures. Under the settlement, it is paying a civil penalty of 48 million USD.

Authority / court

U.S. Commodity Futures Trading Commission (CFTC)

Area of law

Capital markets and financial supervision · Market abuse and insider dealing

Legal basis

Commodity Exchange Act und CFTC-Regulations (versuchte Marktmanipulation)

Action

Fine

Status of proceedings

final

Sector

Energy and utilities

Original amount 48,000,000 USD, converted at the ECB reference rate of 27 Aug 2024.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 27 Aug 2026 · Direct link

From 2014 to April 2019 the US trading company of an international commodity trading group traded gasoline while in possession of confidential information that an employee of a Mexican trading entity had passed on in breach of his duties, and in February 2017 it artificially pushed up the USGC HSFO benchmark by buying 80 cargoes of fuel oil (3.6 million barrels) in the Platts trading window to benefit its own derivatives positions. In addition, broadly drafted confidentiality clauses in employment and separation agreements (2017–2020) hindered employees from contacting the CFTC (U.S. Commodity Futures Trading Commission) directly – according to the regulator, its first action of this kind against a company. Under a settlement, the trader pays a civil monetary penalty of 55,000,000 USD and must amend the clauses.

Authority / court

U.S. Commodity Futures Trading Commission (CFTC)

Area of law

Capital markets and financial supervision · Market abuse and insider dealing

Legal basis

Section 6(c)(1) und Section 23(h)–(j) Commodity Exchange Act; CFTC Regulations 180.1(a)(1), (3) und 165.19

Action

Fine

Status of proceedings

final

Sector

Energy and utilities

Mitigating circumstances

According to the trader, it voluntarily took remedial action (market integrity policies, controls on market-related communications, more training and compliance testing).

Published

17 Jun 2024

Original amount 55,000,000 USD, converted at the ECB reference rate of 17 Jun 2024.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 17 Jun 2026 · Direct link