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.

2cases from 2 jurisdictions
€213.2mTotal of monetary amounts
€143.3mLargest single case: Trafigura Beheer B.V.
€106.6mMedian per case with an amount

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When?

per year, by date of decision
Trend
PeriodCasesTotal
20252€213.2m
20260–

2 cases

28 Mar 2025 Trafigura Beheer B.V.Trafigura Beheer: leniency agreement with CGU and AGU for BRL 435.4m BrazilBribery of public officials €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.

What organisations can take from it

In corruption cases involving several countries, double payments can be avoided through coordinated agreements with all the authorities involved.

Relevance to training and awareness

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.

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

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31 Jan 2025 Trafigura Beheer B.V.Swiss Federal Criminal Court (Bundesstrafgericht) convicts Trafigura of bribery in Angola SwitzerlandBribery of public officials €143.3m

Between 2009 and 2011, more than 4 million EUR and more than 600,000 USD were paid to an official in Angola in order to promote ship chartering and bunkering business of the Trafigura group. The court convicted the then parent company for lacking rules on the supervision of intermediaries, imposing a fine of 3 million CHF and a compensatory claim (Ersatzforderung) of 145,634,268 USD (amount converted at the ECB rate of 31 January 2025: 148,933,982 USD in total). It was the first judgment of the Federal Criminal Court on corporate criminal liability for foreign bribery; it is not final.

What organisations can take from it

In Switzerland, companies are liable if their organisation fails to prevent bribery – and the compensatory claim can exceed the fine many times over.

Relevance to training and awareness

Payments via intermediaries to employees of state-owned oil companies

Authority / court
Bundesstrafgericht (Strafkammer); Anklage durch die Bundesanwaltschaft
Area of law
Bribery and corruption · Bribery of public officials
Legal basis
Art. 102 StGB i. V. m. Art. 322septies StGB (Bestechung fremder Amtsträger); SK.2023.49
Action
Fine
Status of proceedings
unknown
Sector
Energy and utilities
Employees
10,000 or more
Culpability
intentional
Published
31 Jan 2025

Original amount 148,933,982 USD, converted at the ECB reference rate of 31 Jan 2025.

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

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