Compliance Radar

Who was sanctioned, and for what?

Fines, court rulings and incidents from Europe and North America: 756 cases from 32 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.

136cases from 28 jurisdictions
€1.05bnTotal of monetary amounts (121 cases with an amount)
€113mLargest single case: The Toronto-Dominion Bank
€615,000Median per case with an amount

Click a bar to drill down one level.

When?

per quarter, by date of decision
€122.7m€245.4mQ3 2023: 2 cases, €25.4mQ3 2023Q4 2023: 6 cases, €8.17mQ1 2024: 8 cases, €25.2mQ1 2024Q2 2024: 3 cases, €18.4mQ3 2024: 4 cases, €1.9mQ3 2024Q4 2024: 11 cases, €157.3mQ1 2025: 13 cases, €142.3mQ1 2025Q2 2025: 10 cases, €41.4mQ3 2025: 20 cases, €70.1mQ3 2025Q4 2025: 19 cases, €245.4mQ1 2026: 12 cases, €76.9mQ1 2026Q2 2026: 14 cases, €19.6mQ3 2026: 14 cases, €219.6mQ3 2026
Trend
PeriodCasesTotal
Q3 20232€25.4m
Q4 20236€8.17m
Q1 20248€25.2m
Q2 20243€18.4m
Q3 20244€1.9m
Q4 202411€157.3m
Q1 202513€142.3m
Q2 202510€41.4m
Q3 202520€70.1m
Q4 202519€245.4m
Q1 202612€76.9m
Q2 202614€19.6m
Q3 202614€219.6m

136 cases

22 Sep 2026 OTC Link LLCOTC Link: 575,000 USD – security policies never completed despite examination findings USACritical infrastructure €501,614

From 2016 to 2025, the operator of the OTC Link ATS trading system lacked complete policies on systems security, access control and vulnerability management as required under Regulation SCI. Although the examiners of the U.S. Securities and Exchange Commission (SEC) had criticised the gaps in several examinations, drafts remained unfinished; the SEC issued a censure and imposed 575,000 USD.

What organisations can take from it

Track supervisory examination findings with a deadline and a responsible person – points that remain open repeatedly become expensive.

Authority / court
U.S. Securities and Exchange Commission (SEC)
Area of law
Information security and cyber · Critical infrastructure
Legal basis
Regulation SCI, Rule 1001(a)(1)–(3)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Repeat case
yes

Original amount 575,000 USD, converted at the ECB reference rate of 22 Sep 2026.

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

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17 Sep 2026 FleetCor Technologies Inc. (heute Corpay Inc.)FleetCor/Corpay pays 100 million USD over hidden fees on fuel cards USAMisleading advertising and pricing €87.1m

In 2023, a federal court found by way of summary judgment that the fuel card provider had charged its predominantly small business customers hidden or unauthorised fees and misrepresented savings; an appeals court upheld this in 2026. According to the FTC, the fees added up to hundreds of millions of dollars, and late fees were also charged despite punctual payment. Under the settlement resolving the administrative proceedings, FleetCor and CEO Ronald Clarke are paying 100 million USD for refunds; the order is not yet final.

What organisations can take from it

Fees hidden behind links or in account documents are deemed not to have been disclosed – including vis-à-vis business customers.

Authority / court
Federal Trade Commission (FTC)
Area of law
Consumer protection and online retail · Misleading advertising and pricing
Legal basis
Section 5 FTC Act
Action
Disgorgement of profits
Status of proceedings
unknown
Sector
Financial services and insurance
Liability of senior managers
CEO Ronald Clarke is named in the press release as a party involved.
Published
17 Sep 2026

Original amount 100,000,000 USD, converted at the ECB reference rate of 17 Sep 2026.

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

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16 Sep 2026 AIFM Capital ABAIFM Capital: 2 million SEK for inadequate selection and oversight of fund managers SwedenOrganisational requirements €177,187

As a so-called fund hotel, the company had its funds managed by other firms, but examined these delegation agreements only insufficiently, did not take the related decisions properly and did not monitor the funds’ returns in relation to risk closely enough. The Swedish financial supervisory authority Finansinspektionen (FI) issued a remark and imposed 2 million SEK; no damage to investors was established.

What organisations can take from it

Outsourcing tasks does not outsource responsibility: document the selection of service providers, the decisions taken and ongoing oversight.

Authority / court
Finansinspektionen (FI)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Schwedisches Fondsrecht – Regeln zur Delegation der Fondsverwaltung und deren Überwachung
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
No established damage to investors; remedial measures already taken during the investigation.
Published
16 Sep 2026

Original amount 2,000,000 SEK, converted at the ECB reference rate of 16 Sep 2026.

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

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16 Sep 2026 Wallester ASFinancial supervisor orders Wallester to remedy governance and AML deficiencies EstoniaInternal controls Order

Following an on-site inspection, the Finantsinspektsioon (Estonian Financial Supervision Authority) issued an order requiring the payment institution Wallester to remedy, by 31 December, deficiencies in governance and control functions (separation of the lines of defence, internal rules), in safeguarding customer funds and in the staffing of its anti-money laundering and counter-terrorist financing function. Date = publication of the press release.

What organisations can take from it

Fast-growing payment service providers must let their compliance, AML and internal audit functions grow with them in terms of staffing and organisation.

Authority / court
Finantsinspektsioon (Estnische Finanzaufsicht)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Aufsichtsrechtliche Anordnung (ettekirjutus) der Finantsinspektsioon
Action
Order
Status of proceedings
unknown
Sector
Financial services and insurance
Published
16 Sep 2026

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

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3 Sep 2026 Banco Bilbao Vizcaya Argentaria, S.A. – Niederlassung Italien (BBVA Italia)Garante: 5.5 million EUR against BBVA Italia over advertising despite objection ItalyMarketing and consent €5.51m

For seven months (October 2025 to May 2026), the bank continued to send a customer advertising via its app, although he had objected several times. The Italian data protection authority (Garante per la protezione dei dati personali) also found deficient systems for implementing objections and inaccurate information about the processing, and imposed 5,508,000 EUR (Provvedimento No. 613).

What organisations can take from it

An objection to advertising must take effect immediately and reliably across all channels – including app messages.

Authority / court
Garante per la protezione dei dati personali
Area of law
Data protection · Marketing and consent
Legal basis
Art. 5 Abs. 1 lit. a, Art. 12, 21, 24 DSGVO
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
11 Sep 2026

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

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31 Aug 2026 EM@NEY P.L.C.Malta: EM@NEY pays 97,622 EUR under settlement for late bank account register reports MaltaMoney laundering and terrorist financing €97,622

The financial institution did not deliver on time the data due every seven days to the Centralised Bank Account Register (CBAR). The Financial Intelligence Analysis Unit (FIAU) set a fine of 162,704 EUR, which was reduced by 40% to 97,622 EUR under a settlement pursuant to its 2026 settlement policy.

What organisations can take from it

Recurring mandatory reports need deadline monitoring with escalation – otherwise individual omissions add up to six-figure sums.

Authority / court
Financial Intelligence Analysis Unit (FIAU)
Area of law
Money laundering and terrorist financing
Legal basis
Reg. 4(2), 8, 9 CBAR Regulations (S.L. 373.03)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Settlement with 40% reduction
Published
4 Sep 2026

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

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27 Aug 2026 MiFinity Malta LimitedMalta: MiFinity pays 160,099 EUR following anti-money laundering examination MaltaCustomer due diligence €160,099

At the payment institution, the customer risk assessment had only been introduced after business had started, some customers remained unassessed, and customer profiles were based on transaction thresholds rather than on risk. The Financial Intelligence Analysis Unit (FIAU) set a fine of 266,833 EUR and a follow-up directive; under a settlement, the fine was reduced by 40% to 160,099 EUR.

What organisations can take from it

A customer risk assessment belongs before business starts, not in a later remediation project.

Relevance to training and awareness

Risk-based customer profiles and source of funds

Authority / court
Financial Intelligence Analysis Unit (FIAU)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Reg. 2(1), 5(5)(a)(ii), 7(1)(c), 7(2)(a), 21, 22 PMLFTR
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Settlement with 40% reduction; remediation demonstrated
Published
2 Sep 2026

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

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17 Aug 2026 Pluxee Česká republika a.s.; Edenred CZ s.r.o.; Up Česká republika s.r.o.Meal voucher cartel: 279 million CZK against Pluxee, Edenred and Up upheld with final effect CzechiaCartels and collusion €11.5m

From 2004 to 2018, the three issuers of paper meal vouchers coordinated with retail chains how many vouchers would be accepted per purchase. The President of the Úřad pro ochranu hospodářské soutěže (Czech Office for the Protection of Competition, ÚOHS) dismissed the appeals against the recalculation of the fines: Pluxee 132.271 million, Edenred 101.94 million and Up 44.941 million CZK, a total of 279.152 million CZK.

What organisations can take from it

Coordinating seemingly technical conditions such as acceptance limits is also a cartel – industry discussions need clear boundaries.

Relevance to training and awareness

Coordination of terms and conditions among competitors

Authority / court
Úřad pro ochranu hospodářské soutěže (ÚOHS)
Area of law
Competition law · Cartels and collusion
Legal basis
Tschechisches Wettbewerbsgesetz, Art. 101 AEUV (R0112/2025)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Culpability
intentional
Published
17 Aug 2026

Original amount 279,152,000 CZK, converted at the ECB reference rate of 17 Aug 2026.

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

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11 Aug 2026 Citibank, N.A., London BranchOFSI imposes 4.7 million GBP on Citibank London over Russia payments United KingdomBreaches of sanctions and embargoes €5.54m

Mainly between February and November 2022, the London branch processed 970 payments totalling around 19.7 million GBP that breached Russia and anti-corruption sanctions. The causes were overloaded alert handling after the wave of designations, delayed escalation and human error; the bank voluntarily disclosed most of the breaches and received a 20% reduction from HM Treasury's Office of Financial Sanctions Implementation (OFSI).

What organisations can take from it

During waves of designations, alert handling needs additional trained capacity – backlogs and wrong decisions in screening are themselves sanctions breaches.

Relevance to training and awareness

Handling sanctions alerts, escalation and freezing

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; Global Anti-Corruption Sanctions Regulations 2021; s. 146 Policing and Crime Act 2017
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Mitigating circumstances
Predominantly voluntary disclosure and cooperation (20% reduction); exceptional burden caused by the 2022 sanctions packages taken into account
Published
2 Sep 2026

Original amount 4,732,830.58 GBP, converted at the ECB reference rate of 11 Aug 2026.

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

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5 Aug 2026 Order Express, Inc.NYDFS: $250,000 against money transmitter Order Express over cyber deficiencies USA, NYSecurity measures and risk management €216,375

The licensed money transmitter had no adequate policies for system updates and insufficient risk assessments under New York's cybersecurity regulation, as found by the New York State Department of Financial Services (NYDFS). The company has already remedied the deficiencies.

What organisations can take from it

Even small financial service providers must keep documented patch policies and regular risk assessments.

Authority / court
New York State Department of Financial Services (NYDFS)
Area of law
Information security and cyber · Security measures and risk management
Legal basis
23 NYCRR Part 500 (Cybersecurity Regulation)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Because of its low turnover, the company was exempt from many Part 500 obligations; deficiencies already remedied.
Published
5 Aug 2026

Original amount 250,000 USD, converted at the ECB reference rate of 5 Aug 2026.

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

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3 Aug 2026 UBS Financial Services Inc.FinCEN: 125 million USD against UBS Financial Services as a repeat offender USAInternal controls €108.4m

The US Financial Crimes Enforcement Network (FinCEN) imposed 125 million USD on the broker-dealer – the highest BSA penalty against a broker-dealer to date. UBSFS admitted wilful infringements: the AML programme was inadequate, more than 50,000 foreign currency transfers totalling more than 10 billion USD were not adequately monitored and suspicious activity reports were not filed; it is already the second enforcement action after 2018.

What organisations can take from it

Monitoring gaps left unremedied after an earlier enforcement action lead, the second time round, to a multiple of the original penalty.

Authority / court
Financial Crimes Enforcement Network (FinCEN)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Bank Secrecy Act (BSA)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Culpability
intentional
Repeat case
yes
Mitigating circumstances
Up to 15 million USD (remaining amount due by 31 May 2028) may be waived to the extent that UBSFS bears the costs of the independent review of its AML programme and implements its recommendations
Published
3 Aug 2026

Original amount 125,000,000 USD, converted at the ECB reference rate of 3 Aug 2026.

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

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10 Jul 2026 Volksbank Düsseldorf Neuss eGBaFin: 210,000 EUR against Volksbank Düsseldorf Neuss over monitoring and reporting gaps GermanyCustomer due diligence €210,000

Germany's Federal Financial Supervisory Authority (BaFin) imposed fines totalling 210,000 EUR on the cooperative bank: business relationships were not monitored on an ongoing basis or with enhanced scrutiny, additional information was not obtained and suspicious activity reports were not filed or were filed late. The function of the money laundering reporting officer had been outsourced to an external service provider with several clients.

What organisations can take from it

Institutions that outsource the anti-money laundering function remain responsible themselves for ongoing monitoring and timely suspicious activity reports.

Relevance to training and awareness

Ongoing monitoring of business relationships and suspicious activity reporting

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
§ 56 Abs. 1 S. 1 Nr. 20, 36, 38 und 69 GwG; Bekanntmachung nach § 57 GwG
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
17 Sep 2026

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

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10 Jul 2026 Brown Capital Management LLCBrown Capital Management: voting rights notifications not submitted on time GermanyDisclosure and reporting obligations €187,500

The Baltimore-based US asset manager had not submitted voting rights notifications to the issuer and BaFin in time; the deadline is four trading days after reaching a notifiable threshold. BaFin imposed a fine of 187,500 EUR; the notice is final.

What organisations can take from it

Anyone investing in German issuers needs automated threshold monitoring with clear responsibility for the four-day deadline.

Relevance to training and awareness

Threshold monitoring and notification deadlines for shareholdings

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
§ 33 Abs. 1 Satz 1 WpHG
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
22 Jul 2026

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

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2 Jul 2026 Banca Transilvania S.A.Employee retrieves account statements for a third party – Banca Transilvania pays 5,000 EUR RomaniaData breaches and data security €5,002

At the request of a third party and outside the scope of his duties, a bank employee retrieved account statements of a data subject (name, IBAN, transactions, balances). The Romanian data protection authority (ANSPDCP) found insufficient technical and organisational measures and imposed 26,172 lei (5,000 EUR); the bank has paid the fine. Date = publication of the press release; according to the authority, the investigation was concluded in the previous month.

What organisations can take from it

Access logs and clear rules against ‘favour queries’ are a duty for every bank.

Relevance to training and awareness

Access to customer data for business purposes only; handling requests from third parties

Authority / court
Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal (ANSPDCP)
Area of law
Data protection · Data breaches and data security
Legal basis
Art. 32 Abs. 1, 2 und 4 DSGVO
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
2 Jul 2026

Original amount 26,172 RON, converted at the ECB reference rate of 2 Jul 2026.

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

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30 Jun 2026 Moody's Deutschland GmbHESMA fines Moody's Deutschland 2.1 million EUR EU levelOrganisational requirements €2.15m

The credit rating agency did not submit up-to-date rating information to the European Securities and Markets Authority (ESMA), did not provide complete historical performance data to the central repository and lacked adequate procedures and internal control mechanisms. ESMA found negligent infringements and imposed fines totalling 2,145,000 EUR.

What organisations can take from it

Reporting obligations to the supervisory authority are data quality issues – without functioning internal controls, they become a risk of fines.

Authority / court
Europäische Wertpapier- und Marktaufsichtsbehörde (ESMA)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Verordnung (EG) Nr. 1060/2009 (CRA-Verordnung), Art. 24, 36a, Anhang III
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Culpability
negligent
Repeat case
yes

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

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30 Jun 2026 „Paysera LT“, UABPaysera: daily fine for missing annual accounts adds up to 362,000 EUR LithuaniaDisclosure and reporting obligations €362,000

Because Paysera did not comply with the order to submit its 2024 annual financial statements by 30 September 2025, the Lietuvos bankas (Bank of Lithuania, financial supervisor) first imposed 20,000 EUR in November 2025 and then a daily fine of 1,000 EUR (rising to 2,000 and 3,000 EUR respectively). As the infringement was only remedied after 6 May 2026, the daily fine added up to 362,000 EUR. Source: archived copy of the press release.

What organisations can take from it

Running daily fines make every delay expensive – supervisory orders need top-management priority.

Authority / court
Lietuvos bankas (Litauische Zentralbank, Finanzaufsicht)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Aufsichtsrechtliche Anordnung und Berichtspflichten nach litauischem E-Geld-Recht
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Repeat case
yes
Published
30 Jun 2026

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

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26 Jun 2026 Banque Degroof Petercam SABanque Degroof Petercam: 1 million EUR settlement over hidden costs in employee stock options BelgiumOrganisational requirements €1m

In stock option plans for employees of client companies (2018–2023), the bank did not fully inform the beneficiaries about costs, had initially not recorded the conflicts of interest in this business and assessed clients’ knowledge only with a yes/no question. The Autorité des services et marchés financiers (Belgian Financial Services and Markets Authority, FSMA) accepted a settlement of 1 million EUR with publication by name and commitments on cost information.

What organisations can take from it

Full cost transparency and a dedicated conflicts register also apply to ancillary business such as employee stock option plans.

Authority / court
Autorité des services et marchés financiers (FSMA)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Loi du 2 août 2002; Wohlverhaltensregeln (Loyalität, Kostentransparenz, bestmögliche Ausführung, Interessenkonflikte, Kundenkenntnis)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Repeat case
yes
Mitigating circumstances
Remediation of all deficiencies (appropriateness test, conflicts policy, cost disclosure, waiver of CVA/KVA discounts).
Published
26 Jun 2026

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

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23 Jun 2026 Banca Popolare Commerciale SpaBanca d'Italia: 40,000 EUR against Banca Popolare Commerciale over AML deficiencies ItalyCustomer due diligence €40,000

Following an on-site inspection from February to April 2025, the Bank of Italy (Banca d'Italia) found deficiencies in customer due diligence, active cooperation (suspicious transaction reporting) and anti-money laundering controls, and imposed an administrative fine of 40,000 EUR. The duration of the deficiencies and the corrective measures initiated were taken into account.

What organisations can take from it

Gaps in customer due diligence and suspicious transaction reporting are consistently sanctioned after on-site inspections, even with smaller amounts – corrective measures reduce the sanction but do not replace it.

Relevance to training and awareness

Customer due diligence and suspicious transaction reports

Authority / court
Banca d'Italia
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Art. 62 d.lgs. 231/2007; Verstöße gegen Art. 7, 16–19, 24, 25, 35, 36 d.lgs. 231/2007
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
Corrective measures initiated

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

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22 Jun 2026 Inkasso-Team AGFederal Administrative Court upholds FDPIC: Inkasso-Team was not allowed to publish debtor data SwitzerlandData subject rights and transparency Order

The debt collection company posted personal data of alleged debtors on the internet, some of it particularly sensitive, in order to obtain information on their whereabouts and to warn third parties. The Swiss Federal Administrative Court (Bundesverwaltungsgericht, A-3891/2025) upheld the ruling of the Federal Data Protection and Information Commissioner (EDÖB) of 28 April 2025, according to which this constitutes an unjustified violation of privacy.

What organisations can take from it

Publicly naming and shaming debtors cannot be justified under data protection law – debt collection must use less intrusive means.

Authority / court
Bundesverwaltungsgericht (A-3891/2025) auf Verfügung des EDÖB vom 28.04.2025
Area of law
Data protection · Data subject rights and transparency
Legal basis
DSG Art. 6, Art. 19, Art. 31
Action
Order
Status of proceedings
final
Sector
Financial services and insurance
Published
20 Aug 2026

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

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19 Jun 2026 CACEIS Bank (UK Branch)FCA: public censure for CACEIS UK over deficient checks on a custody client United KingdomCustomer due diligence Reprimand or warning

The UK Financial Conduct Authority (FCA) issued a public censure because the London branch opened and operated accounts for the wealth manager WealthTek, although its own register searches showed that it lacked permissions to hold client assets, and overlooked a restriction noted in the register; 16 monitoring alerts were not worked through over two years, and more than £314 million flowed through the accounts. In view of cooperation and a voluntary payment of £31.7 million to WealthTek clients, the FCA refrained from imposing a fine (otherwise £23.1 million after discount).

What organisations can take from it

Anyone who notices a discrepancy in the register must clarify and document it before accounts are activated.

Relevance to training and awareness

Register checks and follow-up on identified KYC gaps

Authority / court
Financial Conduct Authority (FCA)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Section 205 FSMA (Public Censure) wegen Verstoßes gegen FCA Principle 2; Maßstab u. a. SYSC 6.1.1R, 6.3.1R, 6.3.3R und Regulations 18, 27, 28 MLR 2017
Action
Reprimand or warning
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Cooperation, acknowledgement of the deficiencies and a voluntary payment of £31,714,068 to those harmed
Published
25 Jun 2026
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Checked against the official source on 25 Sep 2026 · Direct link

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