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.

Healthcare Clear all filters
93cases from 33 jurisdictions
€565.1mTotal of monetary amounts (69 cases with an amount)
€166.7mLargest single case: Becton, Dickinson and Company (BD)
€1.05mMedian per case with an amount

Click a bar to drill down one level.

Where?

by region

All jurisdictions

  1. USA €411.4m 73 % · 24 cases
  2. EU €134m 24 % · 38 cases
  3. Brazil €12.3m 2 % · 4 cases
  4. Australia €3.69m 1 % · 3 cases
  5. United Kingdom €3.46m 1 % · 15 cases
  6. Norway €133,684 0 % · 1 case
  7. Singapore €47,111 0 % · 1 case
  8. Canada €40,151 0 % · 2 cases
  9. South Africa €5,062 0 % · 2 cases
  10. Hong Kong – 0 % · 1 case
  11. 2 more€0

What for?

by area of law

All areas of law

  1. Bribery and corruption €246.2m 44 % · 18 cases
  2. Capital markets and financial supervision €167m 30 % · 3 cases
  3. Competition law €119.5m 21 % · 14 cases
  4. Data protection €26.3m 5 % · 45 cases
  5. Health and safety and employment law €1.78m 0 % · 5 cases
  6. Sanctions and export control €1.47m 0 % · 1 case
  7. Information security and cyber €1.38m 0 % · 1 case
  8. Whistleblower protection €1.26m 0 % · 1 case
  9. Consumer protection and online retail €133,279 0 % · 4 cases
  10. AI and digital regulation – 0 % · 1 case

Who?

by company
  1. Anonymised companies €221.6m 39 % · 45 cases
  2. Becton, Dickinson and Company (BD) €166.7m 30 % · 1 case
  3. Access DX Laboratory, LLC €31.7m 6 % · 1 case
  4. Advanced Pathology Solutions PLLC und APS MSO LLC €25.9m 5 % · 1 case
  5. C.R. Bard, Inc.; Liberator Medical Supply, Inc.; Liberator Holdings; Rochester Medical Corporation €16.3m 3 % · 1 case
  6. NUWAY Alliance, Inc. €15.8m 3 % · 1 case
  7. Medirex s. r. o.; KLINICKÁ BIOCHÉMIA s.r.o.; Unilabs Slovensko, s. r. o.; synlab slovakia s. r. o.; Asociácia laboratórií €14.6m 3 % · 1 case
  8. Oroville Hospital €9.77m 2 % · 1 case
  9. NeoGenomics Laboratories Inc. €8.59m 2 % · 1 case
  10. PHOENIX Zdravotnícke zásobovanie, a.s.; TRANSMEDIC SLOVAKIA, s.r.o. (in Konkurs) €7.8m 1 % · 1 case
  11. 35 more€46.1m

When?

per year, by date of decision
Trend
PeriodCasesTotal
20225€88.6m
202323€74.5m
202423€235.2m
202518€59.6m
202624€107.1m

93 cases

3 Sep 2026 Azienda Sanitaria Universitaria Friuli Centrale (ASUFC)Garante: Udine hospital group pays 24,000 EUR for viewing a colleague's patient record ItalyEmployee data €24,000

Hospital staff opened a colleague's electronic health record to organise duty rosters during Covid rather than for treatment purposes. Technical barriers limiting access to treating staff were lacking; the Italian data protection authority (Garante per la protezione dei dati personali) imposed 24,000 EUR (Provvedimento No. 616).

What organisations can take from it

Patient records may only be opened for treatment – include this in training and secure it technically through role-based rights and logging.

Relevance to training and awareness

Purpose limitation when accessing patient records

Authority / court
Garante per la protezione dei dati personali
Area of law
Data protection · Employee data
Legal basis
Art. 5 Abs. 1 lit. a, b, c, f, Art. 9, 25, 32 DSGVO; Art. 75 Codice privacy; Linee guida dossier sanitario
Action
Fine
Status of proceedings
unknown
Sector
Healthcare
Published
11 Sep 2026

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

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14 Aug 2026 Plexon, Inc.Plexon: brain research recording systems to listed Chinese military medical academy – 1.7 million USD suspended USAExport control and dual-use goods €1.47m

The neurotechnology company from Dallas, described by the Bureau of Industry and Security (BIS, the export control agency of the US Department of Commerce) as small, delivered neural data acquisition systems (“OmniPlex”) and accessories worth around 179,000 USD on eight occasions in 2022/23 via its Asian distributor to the Chinese Academy of Military Medical Sciences, which has been on the Entity List (the US export control list of restricted parties) since December 2021. The penalty of 1.7 million USD is suspended for five years and then waived, provided that Plexon submits an external audit of its export compliance programme on time and commits no further violations; a five-year denial of export privileges is likewise suspended, and Plexon must also provide export control training.

What organisations can take from it

Screen orders placed via distributors against the Entity List before production – research equipment can also end up with listed military institutions.

Relevance to training and awareness

Entity List screening for orders via distribution partners

Missing or inadequate training played a role in the decision.

Authority / court
U.S. Department of Commerce, Bureau of Industry and Security (BIS)
Area of law
Sanctions and export control · Export control and dual-use goods
Legal basis
Export Administration Regulations, 15 C.F.R. § 764.2(a), § 744.11
Action
Fine
Status of proceedings
final
Sector
Healthcare
Mitigating circumstances
Penalty and denial of export privileges fully suspended for five years, conditional on an external export control audit.
Published
14 Aug 2026

Original amount 1,700,000 USD, converted at the ECB reference rate of 14 Aug 2026.

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

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30 Jul 2026 Access DX Laboratory, LLCAccess DX Laboratory: 36.4 million USD – kickbacks for unnecessary genetic tests USACommercial bribery €31.7m

The Houston laboratory allegedly paid kickbacks and billed Medicare and Medicaid for medically unnecessary genetic tests. The settlements with the laboratory and other parties add up to 36.4 million USD (combined total); the laboratory is subject to a Corporate Integrity Agreement.

What organisations can take from it

Commission models for intermediaries who bring in orders or patients are a classic gateway for bribery.

Relevance to training and awareness

Remuneration of intermediaries and referrers

Authority / court
U.S. Department of Justice
Area of law
Bribery and corruption · Commercial bribery
Legal basis
Anti-Kickback Statute (42 U.S.C. § 1320a-7b(b)); False Claims Act (31 U.S.C. §§ 3729 ff.)
Action
Other
Status of proceedings
final
Sector
Healthcare
Liability of senior managers
Measures against individuals are not reported here.

Original amount 36,400,000 USD, converted at the ECB reference rate of 30 Jul 2026.

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

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21 Jul 2026 Hôpital Privé de la LoireHôpital Privé de la Loire: 500,000 EUR after data exfiltration affecting over 520,000 patients FranceData breaches and data security €500,000

In summer 2025, an attacker gained access to the private hospital's electronic patient record system and obtained data on 524,867 patients and 202,246 trusted persons. There was no VPN or multi-factor authentication for external users, no appropriate access control and no detection of suspicious activity; the trusted persons were not notified. France's data protection authority (Commission nationale de l'informatique et des libertés, CNIL) imposed a fine of 500,000 EUR (SAN-2026-009).

What organisations can take from it

External access to patient records belongs behind multi-factor authentication and continuous monitoring for unusual access.

Relevance to training and awareness

Access security and attack detection in hospitals

Authority / court
Commission nationale de l'informatique et des libertés (CNIL)
Area of law
Data protection · Data breaches and data security
Legal basis
DSGVO Art. 32, Art. 34
Action
Fine
Status of proceedings
final
Sector
Healthcare
Published
3 Sep 2026

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

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20 Jul 2026 NeoGenomics Laboratories Inc.NeoGenomics: 9.8 million USD after self-disclosure – discounted consulting for referring physicians USACommercial bribery €8.59m

The Florida laboratory provided referring physicians with consulting services below market value and paid independent consultants referral-based remuneration for recruiting physicians. Following a self-disclosure, NeoGenomics paid 9,813,260 USD.

What organisations can take from it

Free or discounted services are also benefits – like cash payments, they belong in the anti-corruption review.

Relevance to training and awareness

Services with monetary value provided to customers below market value

Authority / court
U.S. Department of Justice
Area of law
Bribery and corruption · Commercial bribery
Legal basis
Anti-Kickback Statute (42 U.S.C. § 1320a-7b(b)); False Claims Act (31 U.S.C. §§ 3729 ff.)
Action
Other
Status of proceedings
final
Sector
Healthcare
Mitigating circumstances
Self-disclosure of the remuneration arrangements.

Original amount 9,813,260 USD, converted at the ECB reference rate of 20 Jul 2026.

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

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7 Jul 2026 Γενικό Νοσοκομείο Θεσσαλονίκης Γ. Γεννηματάς «Ο Άγιος Δημήτριος» (Allgemeines Krankenhaus Thessaloniki G. Gennimatas – Agios Dimitrios)Thessaloniki hospital: 25,000 EUR because surgery lists with diagnoses were online GreeceData breaches and data security €25,000

From May to the end of August 2024, the public hospital accidentally published on its website a surgery list containing patients' telephone numbers, illnesses and planned procedures; a member of the public found the document via Google. The Hellenic Data Protection Authority imposed a total of 25,000 EUR: 10,000 EUR for inadequate security, 2,000 EUR for the late notification, 10,000 EUR for failing to notify the data subjects and 3,000 EUR for missing contact details of the data protection officer (DPO).

What organisations can take from it

Every publication on the website needs an approval step that reliably intercepts documents containing health data – and after a data breach, data subjects must be informed.

Relevance to training and awareness

Publication of documents containing health data

Authority / court
Αρχή Προστασίας Δεδομένων Προσωπικού Χαρακτήρα (Hellenic Data Protection Authority)
Area of law
Data protection · Data breaches and data security
Legal basis
DSGVO Art. 5 Abs. 1 lit. f, 32 Abs. 1, 33 Abs. 1, 34 Abs. 1, 12, 13 i. V. m. 37 (Entscheidung 13/2026)
Action
Fine
Status of proceedings
final
Sector
Healthcare

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

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25 Jun 2026 Самостоятелна медико-диагностична лаборатория „Лина“ ЕООДLaboratory Lina lures customers with free blood tests – 52,097 EUR for unfair competition BulgariaCompetition law €52,097

On application by a competitor, the Комисия за защита на конкуренцията (Bulgarian Commission for the Protection of Competition, KZK) established that the laboratory had offered packages of medical laboratory tests free of charge nationwide over extended periods (only against a fee of 2 leva for taking blood) – conduct shown by no other market participant outside joint campaigns. It found an infringement of the general clause of unfair competition law (Art. 29 ZZK – Bulgarian Protection of Competition Act) and imposed 0.3% of 2024 turnover, i.e. 52,096.55 EUR. Appeals have been lodged against the decision.

What organisations can take from it

Permanent free offers to win customers can be unfair if they deviate significantly from market practice and drive out competitors.

Authority / court
Комисия за защита на конкуренцията (КЗК, Bulgarische Wettbewerbskommission)
Area of law
Competition law
Legal basis
Art. 29 ZZK (Generalklausel unlauterer Wettbewerb)
Action
Fine
Status of proceedings
under appeal
Sector
Healthcare
Published
2 Jul 2026

Checked against the official source on 28 Sep 2026 · Version 2 · Direct link

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18 Jun 2026 St. Joseph's Healthcare HamiltonHamilton hospital: CA$65,000 after injury caused by known centrifuge defect Canada, ONWorkplace safety and accidents €40,151

In the teaching hospital's virology laboratory, the lid of a centrifuge fell on an employee who had to hold it open by hand because of a defective gas spring; she was seriously injured. Maintenance reports from 2023 and 2024 had already called for the spring to be replaced. Fine of CA$65,000 plus victim fine surcharge.

What organisations can take from it

A defect documented in maintenance reports that is not remedied makes every subsequent accident foreseeable – defective equipment must be taken out of use.

Relevance to training and awareness

Reporting defective equipment and taking it out of service

Authority / court
Provincial Offences Court Hamilton (Ermittlung: Ontario Ministry of Labour, Immigration, Training and Skills Development)
Area of law
Health and safety and employment law · Workplace safety and accidents
Legal basis
Section 25(1)(b) Occupational Health and Safety Act (Ontario)
Action
Fine
Status of proceedings
final
Sector
Healthcare
Mitigating circumstances
Guilty plea; repair two days after the accident.
Published
21 Jul 2026

Original amount 65,000 CAD, converted at the ECB reference rate of 18 Jun 2026.

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

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17 Jun 2026 Advanced Pathology Solutions PLLC und APS MSO LLCAdvanced Pathology Solutions: 30 million USD for kickbacks and unnecessary laboratory tests USACommercial bribery €25.9m

The Arkansas pathology laboratory and its management company allegedly granted unlawful kickbacks and ordered medically unnecessary tests. The settlement of 30 million USD is a joint payment by all settling parties; the laboratory entered into a Corporate Integrity Agreement.

What organisations can take from it

Where services are sold through referrals, all benefits to referrers belong in a central approval and review procedure.

Relevance to training and awareness

Benefits to clients in healthcare

Authority / court
U.S. Department of Justice
Area of law
Bribery and corruption · Commercial bribery
Legal basis
Anti-Kickback Statute (42 U.S.C. § 1320a-7b(b)); False Claims Act (31 U.S.C. §§ 3729 ff.)
Action
Other
Status of proceedings
final
Sector
Healthcare
Liability of senior managers
Measures against individuals are not reported here.

Original amount 30,000,000 USD, converted at the ECB reference rate of 17 Jun 2026.

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

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11 Jun 2026 Monash IVF Pty LtdMonash IVF: tracking pixels on fertility website used without consent AustraliaCookies and tracking Order

Monash IVF collected sensitive information about visitors to its fertility treatment website through third-party tracking pixels. The Privacy Commissioner held that following the visitors of health-related websites and afterwards showing them targeted adverts on social networks amounts to collecting sensitive data, which requires consent, and found breaches of APP 3.3, 5.1, 5.2 and 7.1. Monash IVF must not continue or repeat the conduct and must implement specified remedial steps; a parallel determination against the telehealth provider Medmate Australia was made on the same day.

What organisations can take from it

Anyone using tracking pixels on health websites needs visitors' consent and must know which data flows to advertising platforms.

Relevance to training and awareness

Tracking pixels and advertising tools on websites with sensitive content

Authority / court
Office of the Australian Information Commissioner (OAIC)
Area of law
Data protection · Cookies and tracking
Legal basis
Privacy Act 1988 (Cth), APP 3.3, 5.1, 5.2, 7.1
Action
Order
Status of proceedings
unknown
Sector
Healthcare
Published
24 Jun 2026

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

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10 Jun 2026 Health Service Executive (HSE)DPC: €300,000 fine against HSE after ransomware attack on hospital laboratory in Tullamore IrelandData breaches and data security €300,000

In November 2018 attackers encrypted patient data in the laboratory information system of Midlands Regional Hospital Tullamore. The DPC found that the HSE had infringed Art. 5(1)(f), 28, 30, 32(1) and 34 GDPR (including insufficient security, deficient processor contracts and record of processing, and incomplete notification of affected persons), issued a reprimand, imposed €300,000 for the security failings (Art. 5(1)(f) and 32(1)) and ordered it to introduce specified policies and procedures for secure processing.

What organisations can take from it

Laboratory and other specialist hospital systems also belong in security and supplier management; contracts with processors must contain the GDPR safeguards.

Relevance to training and awareness

Ransomware protection of clinical systems

Authority / court
Data Protection Commission (DPC)
Area of law
Data protection · Data breaches and data security
Legal basis
Art. 5(1)(f), 28, 30, 32(1), 34 DSGVO
Action
Fine
Status of proceedings
unknown
Sector
Healthcare

Checked against the official source on 2 Oct 2026 · Direct link

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2 Jun 2026 Ascension Health Alliance; AmSurg LLC / Ambulatory Topco LLCAscension/AmSurg: seven ambulatory surgery centres must be sold USAMerger control Order

The non-profit hospital group Ascension wanted to acquire AmSurg for 3.9 billion USD. Owing to overlaps in outpatient surgery in five regions, the Federal Trade Commission (FTC) requires the sale of seven AmSurg centres to SC Affiliates and a gastroenterology practice, as well as transitional support.

What organisations can take from it

Non-profit healthcare providers are also subject to merger control – regional market shares determine divestitures.

Authority / court
Federal Trade Commission (FTC)
Area of law
Competition law · Merger control
Legal basis
Section 7 Clayton Act; Section 5 FTC Act (Consent Order)
Action
Order
Status of proceedings
unknown
Sector
Healthcare
Employees
10,000 or more

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

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26 May 2026 IQVIA Operations FranceCNIL: €5m fine for IQVIA Operations France over health data warehouses FranceData subject rights and transparency €5m

The CNIL (French data protection authority) fined IQVIA Operations France EUR 5,000,000 because, for two health data warehouses authorised by the CNIL (fed with data from around 14,000 pharmacies and several thousand medical practices), the company did not comply with the conditions of the authorisations, including log analysis, multi-factor authentication, patient information and the right to object. In addition, pharmacy customers were not informed of the transfer of their data, in-house studies were carried out without the required authorisation and the pharmacy software transmitted data even after a refusal (Art. 25 GDPR). The CNIL classified the data as pseudonymised rather than anonymous and ordered remedial action within six months, subject to a penalty payment of EUR 10,000 per day.

What organisations can take from it

Anyone working with authorised health data must implement the conditions of the authorisation technically as well and actively monitor how partners inform the individuals concerned.

Relevance to training and awareness

Conditions for processing health data

Authority / court
Commission nationale de l'informatique et des libertés (CNIL), formation restreinte
Area of law
Data protection · Data subject rights and transparency
Legal basis
Art. 66 Loi n° 78-17 du 6 janvier 1978 (Loi Informatique et Libertés); Art. 14 und 25 DSGVO
Action
Fine
Status of proceedings
unknown
Sector
Healthcare
Culpability
negligent
Mitigating circumstances
The security shortcomings were remedied after the inspections.
Published
28 May 2026

Checked against the official source on 2 Oct 2026 · Direct link

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1 May 2026 Modern Nuclear Inc.Modern Nuclear: 8.33 million USD – excessive supervision fees paid to referring cardiologists USACommercial bribery €7.12m

The Californian provider of mobile PET scans allegedly paid referring cardiologists excessive fees for supervising the examinations in order to secure referrals. The settlement of 8,334,350.71 USD plus revenue-based payments is based on ability to pay; in addition, there is a Corporate Integrity Agreement.

What organisations can take from it

Remuneration of business partners who refer work must correspond to the market value of the service – any overpayment acts as a bribe.

Relevance to training and awareness

Checking fee agreements with referrers for market conformity

Authority / court
U.S. Department of Justice / U.S. Attorney's Office, Central District of California
Area of law
Bribery and corruption · Commercial bribery
Legal basis
Anti-Kickback Statute (42 U.S.C. § 1320a-7b(b)); False Claims Act (31 U.S.C. §§ 3729 ff.)
Action
Other
Status of proceedings
final
Sector
Healthcare

Original amount 8,334,350.71 USD, converted at the ECB reference rate of 30 Apr 2026.

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

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1 May 2026 LiveBetter Services LimitedLiveBetter Services: 675,000 AUD after fatal scalding of an NDIS participant AustraliaWorkplace safety and accidents €412,314

Following an investigation by SafeWork NSW, the District Court of NSW fined LiveBetter Services Limited 675,000 AUD for a breach of ss 32/19(2) of the Work Health and Safety Act 2011. In February 2022, a participant in the National Disability Insurance Scheme (NDIS) was placed in a bath with excessively hot water, suffered serious burns and died from her injuries.

What organisations can take from it

When bathing people in care, water temperature must be limited by technical means and checked before every bath.

Relevance to training and awareness

Preventing scalds in care and support services

Authority / court
SafeWork NSW
Area of law
Health and safety and employment law · Workplace safety and accidents
Legal basis
Work Health and Safety Act 2011 (NSW) ss 32/19(2)
Action
Fine
Status of proceedings
unknown
Sector
Healthcare

Original amount 675,000 AUD, converted at the ECB reference rate of 30 Apr 2026.

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

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17 Apr 2026 Medirex s. r. o.; KLINICKÁ BIOCHÉMIA s.r.o.; Unilabs Slovensko, s. r. o.; synlab slovakia s. r. o.; Asociácia laboratóriíLaboratory cartel: 14.6 million EUR and procurement bans against diagnostic laboratories SlovakiaCartels and collusion €14.6m

Four laboratories and their association coordinated negotiations on prices with health insurers, coordinated in tenders, exchanged sensitive information and allocated customers. At first instance, the Protimonopolný úrad Slovenskej republiky (Antimonopoly Office of the Slovak Republic, PMÚ SR) imposed 14,551,800 EUR and three-year procurement bans; Unilabs received a substantially reduced fine as leniency applicant and under a settlement.

What organisations can take from it

Common negotiating positions towards payers via an association are a cartel – association meetings need minutes and a review of the agenda.

Relevance to training and awareness

Information exchange among competitors and association work

Authority / court
Protimonopolný úrad Slovenskej republiky (PMÚ SR)
Area of law
Competition law · Cartels and collusion
Legal basis
Slowakisches Wettbewerbsschutzgesetz (Kartellverbot)
Action
Fine
Status of proceedings
unknown
Sector
Healthcare
Culpability
intentional
Mitigating circumstances
Unilabs: leniency reduction (50%) and settlement (a further 30%).
Published
12 May 2026

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

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16 Apr 2026 Fullgevity OÜ (vormals Zahnarztpraxis unter Inhabernamen, anonymisiert)Fullgevity (dental clinic) must reorganise data processing in Invisalign treatment EstoniaData processors Order

The starting point was a complaint about incomplete disclosure of patient data; the clinic left several requests from the supervisory authority unanswered. The Andmekaitse Inspektsioon (Estonian Data Protection Inspectorate, AKI) ordered it to revise its contracts with Align Technology (Invisalign) with regard to the GDPR roles (Art. 26/28 GDPR), to adapt the consent form and the privacy notices in accordance with Art. 7, 9, 13 and 14 GDPR and to publish them in Estonian; non-compliance is subject to a penalty payment of 1,000 EUR per item.

What organisations can take from it

Anyone passing patient data on to manufacturers or platforms must clarify roles, contracts and consents properly in advance – and respond to supervisory requests on time.

Relevance to training and awareness

Consent and transparency for health data; cooperation with the supervisory authority

Authority / court
Andmekaitse Inspektsioon (AKI)
Area of law
Data protection · Data processors
Legal basis
§ 56 Abs. 1 IKS; Art. 58 Abs. 2 lit. d DSGVO i. V. m. Art. 5 Abs. 1 lit. a, 7, 9, 13, 14, 26, 28 DSGVO
Action
Order
Status of proceedings
unknown
Sector
Healthcare

Checked against the official source on 28 Sep 2026 · Version 2 · Direct link

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20 Mar 2026 Gesundheitsdienstleister (in der Entscheidung anonymisiert)Hungarian GP practice: 500,000 HUF for 47 EESZT queries without legal basis HungaryData subject rights and transparency €1,274

A general practitioner who had no longer been treating the complainant since January 2023 accessed his health data (findings, prescriptions) on the national e-health platform EESZT a total of 47 times via his practice software until August 2024 and did not respond to an access request. The Hungarian data protection authority (Nemzeti Adatvédelmi és Információszabadság Hatóság, NAIH) found infringements of Art. 5(2), 6(1), 9(2), 12(2) and 15(1) GDPR, ordered compliance with the access request and imposed 500,000 HUF.

What organisations can take from it

Every access to electronic health records is logged and must be linked to treatment – even if it is triggered by practice staff.

Relevance to training and awareness

Access to health data and access requests

Authority / court
Nemzeti Adatvédelmi és Információszabadság Hatóság (NAIH)
Area of law
Data protection · Data subject rights and transparency
Legal basis
DSGVO Art. 5 Abs. 2, 6 Abs. 1, 9 Abs. 2, 12 Abs. 2, 15 Abs. 1
Action
Fine
Status of proceedings
final
Sector
Healthcare
Published
20 Mar 2026

Original amount 500,000 HUF, converted at the ECB reference rate of 20 Mar 2026.

Checked against the official source on 28 Sep 2026 · Version 2 · Direct link

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19 Mar 2026 Balt USA LLC (Balt-Gruppe)Balt USA: CJIP in France over payments to a hospital physician FranceBribery of public officials €1.77m

In parallel with the US declination, the PNF concluded a CJIP with the US subsidiary of the French medical technology manufacturer for 1,765,493 EUR (after crediting the US disgorgement) and a three-year AFA compliance programme. The case arose from Balt SAS's voluntary self-disclosure of 22 May 2023 concerning conduct at the acquired company Blockade Medical.

What organisations can take from it

Acquisitions require anti-corruption due diligence on the target company – otherwise legacy misconduct by its management becomes a group risk.

Relevance to training and awareness

Benefits to hospital physicians, integration of acquired companies

Authority / court
Parquet national financier (PNF); Validierung durch den Präsidenten des Tribunal judiciaire de Paris
Area of law
Bribery and corruption · Bribery of public officials
Legal basis
Art. 41-1-2 Code de procédure pénale (CJIP); aktive und passive Bestechung von Amtsträgern
Action
Fine
Status of proceedings
final
Sector
Healthcare
Employees
250 to 999
Culpability
intentional
Mitigating circumstances
Voluntary self-disclosure to the PNF and the DOJ; coordinated resolution with crediting.
Liability of senior managers
The CJIP does not address the criminal liability of natural persons.
Published
19 Mar 2026

Checked against the official source on 28 Sep 2026 · Version 2 · Direct link

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17 Mar 2026 Balt SAS / Balt USA LLCMedical technology: DOJ declination for Balt SAS after bribery of a hospital physician USABribery of public officials €1.05m

Through sham consultancy agreements, fictitious invoices and purported bonus payments, around 602,000 USD in bribes flowed from 2017 to 2023 via a Belgian consultant to a physician in a senior position at a French public hospital, so that the hospital would purchase embolisation coils from Balt. The DOJ declined to prosecute on account of voluntary self-disclosure, cooperation and remediation (declination of 17 March 2026); Balt is disgorging 1,214,797 USD in profits.

What organisations can take from it

Physicians at public hospitals are public officials – consultancy agreements with them require documented services and approval by the compliance function.

Relevance to training and awareness

Benefits to physicians in the public healthcare sector, sham consultancy agreements

Authority / court
U.S. Department of Justice (Criminal Division, Fraud Section)
Area of law
Bribery and corruption · Bribery of public officials
Legal basis
FCPA; Corporate Enforcement and Voluntary Self-Disclosure Policy (Declination)
Action
Disgorgement of profits
Status of proceedings
final
Sector
Healthcare
Culpability
intentional
Mitigating circumstances
Voluntary self-disclosure (including to the French national financial prosecutor's office, PNF), full cooperation, timely remediation, disciplinary measures, parallel resolution in France.
Liability of senior managers
Measures against individuals are not reported here.
Published
19 Mar 2026

Original amount 1,214,797 USD, converted at the ECB reference rate of 17 Mar 2026.

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

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