Compliance Radar
Who was sanctioned, and for what?
Fines, court rulings and incidents from Europe and North America: 718 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.
Click a bar to drill down one level.
Where?
by regionAll jurisdictions
What for?
by area of lawAll areas of law
- Sanctions and export control 6 cases 32 % · €223m
- Capital markets and financial supervision 3 cases 16 % · €900,000
- Competition law 3 cases 16 % · €97.9m
- Bribery and corruption 3 cases 16 % · €11.1m
- Supply chain and human rights 2 cases 11 % · €368,909
- Health and safety and employment law 1 case 5 % · €100,000
- Data protection 1 case 5 % · €7,000
Who?
by company- Airbus Operations Limited 1 case 6 % · €7.48m
- Applied Materials, Inc. und Applied Materials Korea, Ltd. 1 case 6 % · €212.2m
- CalPlus GmbH, Elektronik-Kontor Messtechnik GmbH, TVW Meßtechnik GmbH 1 case 6 % · €453,000
- Container Manufacturing Ltd. 1 case 6 % · €857,339
- Deere & Company 1 case 6 % · €9m
- ELKOND HHK, VUKI, Prysmian, NKT, KABEX u. a. (Kabelkartell, 9 Unternehmen und ein Verband) 1 case 6 % · €97.4m
- Giant Manufacturing Co. Ltd. 1 case 6 % ·
- Haas Automation, Inc. 1 case 6 % · €2.47m
- KION Group AG 1 case 6 % · €280,000
- KLUBB France SAS 1 case 6 % · €558,024
- 6 more6 cases
When?
per quarter, by date of decision| Period | Cases | Total |
|---|---|---|
| Q3 2023 | 0 | — |
| Q4 2023 | 1 | €280,000 |
| Q1 2024 | 1 | — |
| Q2 2024 | 0 | — |
| Q3 2024 | 1 | €9m |
| Q4 2024 | 3 | €1.91m |
| Q1 2025 | 3 | €3.13m |
| Q2 2025 | 2 | €7,000 |
| Q3 2025 | 1 | — |
| Q4 2025 | 0 | — |
| Q1 2026 | 2 | €309.6m |
| Q2 2026 | 1 | €620,000 |
| Q3 2026 | 4 | €8.84m |
19 cases
11 Feb 2026 Applied Materials, Inc. und Applied Materials Korea, Ltd.Applied Materials pays 252 million USD for chip equipment exports to China €212.2m
In 2021 and 2022, Applied Materials and its Korean subsidiary exported ion implanters for semiconductor manufacturing worth around 126 million USD via Korea without a licence to a Chinese company placed on the Entity List in 2020. The penalty imposed by the US Commerce Department's Bureau of Industry and Security (BIS) corresponds to twice the transaction value and thus the statutory maximum; the compliance staff and executives responsible are no longer with the company.
Routing through foreign subsidiaries does not remove the licence requirement; export control needs audits and clear accountability of management.
Entity List screening for deliveries via subsidiaries
- 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 (Entity List)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Manufacturing and mechanical engineering
- Employees
- 10,000 or more
- Liability of senior managers
- According to BIS, the responsible compliance staff and senior executives from sales and production are no longer employed.
- Published
- 12 Feb 2026
Original amount 252,500,300 USD, converted at the ECB reference rate of 11 Feb 2026.
- BIS: Applied Materials to Pay $252 Million Penalty for Illegally Exporting Semiconductor Manufacturing Equipment (12.02.2026) Press release of an authority
- BIS Order Relating to Applied Materials, Inc. and Applied Materials Korea (11.02.2026) Decision of an authority
Checked against the official source on 25 Sep 2026 · Direct link
Report an error
24 Aug 2026 Container Manufacturing Ltd.Small US machinery supplier exported spare parts for can presses to Russia €857,339
Between March 2023 and March 2025, the Ohio manufacturer of presses for beverage can ends (nine employees) supplied, in ten instances, spare parts for aluminium forming tools worth around 264,700 USD – partly via the UAE and Turkey – without a licence to a Russian customer whose group also supplies defence precursors. In two instances, the company acted with knowledge of the violation; it admitted the allegations, which were brought by the US Commerce Department's Bureau of Industry and Security (BIS).
Even small businesses with few employees must check tariff codes against Russia restrictions and treat deliveries via third countries as a warning sign.
HTS-based export restrictions on Russia, diversion via third countries
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, § 746.8(a)(5) (HTS-Codes Supplement No. 4 to Part 746), §§ 764.2(a), 764.2(e)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Manufacturing and mechanical engineering
- Employees
- Under 50
- Mitigating circumstances
- Full cooperation; compliance programme subsequently expanded with screening, an approval process and additional export control training
- Published
- 24 Aug 2026
Original amount 1,000,000 USD, converted at the ECB reference rate of 24 Aug 2026.
- BIS Reaches Administrative Enforcement Settlement with Container Manufacturing Ltd. (24.08.2026) Press release of an authority
- BIS Order Relating to Container Manufacturing Ltd. Decision of an authority
Checked against the official source on 25 Sep 2026 · Direct link
Report an error
12 Aug 2026 Rice Lake Weighing Systems, Inc.Scale manufacturer Rice Lake liable for Italian subsidiary's indirect exports to Iran €52,632
In eight instances in 2019–2021, the Italian subsidiary Dini Argeo supplied weighing equipment worth around 121,500 USD to a trader in the UAE, although it knew that the goods would be passed on to a former direct Iranian customer. The parent company had passed on the Iran ban only by an English-language e-mail without explanation; the US Treasury's Office of Foreign Assets Control (OFAC) considered it a non-egregious, voluntarily self-disclosed case.
Implement sanctions requirements at foreign subsidiaries in an understandable way, in the local language and with training for all relevant employees – indirect supplies via traders are also prohibited.
Sanctions training for foreign subsidiaries, indirect supplies via third countries
Missing or inadequate training played a role in the decision.
- 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, § 560.215 (Auslandstöchter von US-Personen)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Manufacturing and mechanical engineering
- Culpability
- negligent
- Repeat case
- no
- Mitigating circumstances
- Voluntary self-disclosure, immediate internal investigation, low significance for turnover, no prior violations, cooperation; subsequent training of the subsidiary's employees and screening of traders
- Published
- 12 Aug 2026
Original amount 60,764 USD, converted at the ECB reference rate of 12 Aug 2026.
- OFAC Enforcement Release: Rice Lake Weighing Systems Settles with OFAC for Iran-Related Apparent Violations (12.08.2026) Decision of an authority
- OFAC – Civil Penalties and Enforcement Information Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
Report an error
30 Jul 2026 Airbus Operations LimitedAirbus Operations pays 6.4 million GBP for export control breaches in technology transfer €7.48m
Over an extended period before November 2022, Airbus Operations Ltd breached the Export Control Order 2008: transfers of controlled technology under three open general export licences (OGEL) were not correctly documented, required registers were missing, and one individual licence was not complied with. The case came to light through voluntary disclosure and was concluded by HM Revenue & Customs (HMRC) by way of a compound settlement (date of publication).
Technology transfers by e-mail or data room are also exports – conditions, registers and records of general licences must be put into practice day to day.
Licence conditions and record-keeping obligations in technology transfer
- Authority / court
- HM Revenue & Customs (HMRC) / Export Control Joint Unit
- Area of law
- Sanctions and export control · Export control and dual-use goods
- Legal basis
- Export Control Order 2008, Art. 29(2) und 29(3) (Auflagen und Register bei OGELs) sowie Auflage einer SIEL; Straftaten nach Art. 38(1)(a) und (b); Compound Settlement durch HMRC
- Action
- Fine
- Status of proceedings
- final
- Sector
- Manufacturing and mechanical engineering
- Employees
- 10,000 or more
- Mitigating circumstances
- Voluntary disclosure, full cooperation, remedial measures
- Published
- 30 Jul 2026
Original amount 6,409,388 GBP, converted at the ECB reference rate of 30 Jul 2026.
- Notice to exporters 2026/17: company named in compound settlement for breaches of export control Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
Report an error
15 Jul 2026 CalPlus GmbH, Elektronik-Kontor Messtechnik GmbH, TVW Meßtechnik GmbHBundeskartellamt: 453,000 EUR against distributors of test and measuring equipment €453,000
From 2016 to 2022, three distributors of test and measuring equipment coordinated discounts as essential price components and informed each other of customer contacts, usually with a request for "restraint". This was evidenced by more than 400 emails; the proceedings ended in settlements.
Small distributors are liable too: merely asking a competitor to "hold back" with a customer is a prohibited customer allocation agreement.
Email contacts with competitors about customers and discounts
- Authority / court
- Bundeskartellamt
- Area of law
- Competition law · Cartels and collusion
- Legal basis
- § 1 GWB
- Action
- Fine
- Status of proceedings
- final
- Sector
- Manufacturing and mechanical engineering
- Mitigating circumstances
- Settlement; cooperation by Elektronik-Kontor Messtechnik taken into account
- Published
- 15 Jul 2026
- Bundeskartellamt verhängt Bußgelder wegen Preisabsprachen beim Vertrieb von Prüf- und Messgeräten Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
Report an error
23 Jun 2026 VARTA AGVARTA: late ad hoc announcement and missing half-yearly financial report €620,000
BaFin imposed fines on the battery manufacturer because it had not disclosed inside information without delay and had not published the half-yearly financial report for the 2024 financial year.
Ad hoc assessments and periodic disclosure require fixed responsibilities and deadline controls so that neither inside information nor mandatory reports are left pending.
- Authority / court
- Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
- Area of law
- Capital markets and financial supervision · Disclosure and reporting obligations
- Legal basis
- Art. 17 Abs. 1 UAbs. 1 MAR; § 115 Abs. 1 Satz 1 WpHG
- Action
- Fine
- Status of proceedings
- final
- Sector
- Manufacturing and mechanical engineering
- Published
- 1 Jul 2026
- VARTA AG: BaFin setzt Geldbußen fest Decision of an authority
- Bekanntmachung der BaFin zur VARTA AG (Maßnahmenansicht mit Rechtskraftvermerk) Official register or notice
Checked against the official source on 25 Sep 2026 · Direct link
Report an error
12 Feb 2026 ELKOND HHK, VUKI, Prysmian, NKT, KABEX u. a. (Kabelkartell, 9 Unternehmen und ein Verband)Cable cartel: PMÚ imposes record fines of 97.4 million EUR €97.4m
Manufacturers and suppliers of copper and aluminium cables coordinated a common calculation of the metal surcharge, which makes up a significant part of the final price; an industry association acted as facilitator. The Protimonopolný úrad Slovenskej republiky (Antimonopoly Office of the Slovak Republic, PMÚ SR) imposed a total of 97,434,800 EUR, the highest amount in a single proceeding; two leniency applicants were not fined (not final). Addressees: ELKOND HHK, a.s.; VUKI a.s.; Prysmian Kablo s.r.o.; Prysmian Kabely, s.r.o.; Kablo Vrchlabí s.r.o.; NKT s.r.o.; PRECON s.r.o.; Tele–Fonika Kabely CZ s.r.o.; KABELOVNA KABEX a. s.; Asociace výrobců kabelů a vodičů ČR a SR (leniency applicants without a fine: ICS Industrial Cables Slovakia, PRAKAB).
A coordinated calculation formula for price components is also price fixing – association work needs competition law support.
Price coordination via associations and surcharge formulas
- 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
- Manufacturing and mechanical engineering
- Culpability
- intentional
- Published
- 11 Mar 2026
- KARTELY: PMÚ odhalil kartel výrobcov a dodávateľov káblov, uložil pokuty takmer 100 miliónov eur Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
Report an error
24 Sep 2025 Giant Manufacturing Co. Ltd.CBP detains bicycles from Giant Manufacturing over forced labour Order
U.S. Customs and Border Protection (CBP) issued a Withhold Release Order: bicycles, bicycle parts and accessories from Giant Manufacturing Co. Ltd. (Taiwan) are being detained at all US ports of entry because there are indications of forced labour (ILO indicators including debt bondage, withholding of wages, excessive overtime and abusive working and living conditions). Detained shipments can be destroyed, re-exported or released upon proof of admissibility.
Recruitment fees for migrant workers are a core risk – suppliers should demonstrably bear them themselves.
- Authority / court
- U.S. Customs and Border Protection
- Area of law
- Supply chain and human rights · Forced and child labour
- Legal basis
- 19 U.S.C. § 1307 (Tariff Act of 1930, Section 307)
- Action
- Order
- Status of proceedings
- unknown
- Sector
- Manufacturing and mechanical engineering
- Published
- 24 Sep 2025
- CBP issues Withhold Release Order on Giant Manufacturing Co. Ltd. Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
Report an error
17 Jun 2025 Safran S.A.Safran/Collins: clearance only in exchange for sale of actuation businesses Order
The Competition and Markets Authority (CMA) found that Safran’s acquisition of part of the actuation and flight control business of Collins Aerospace (RTX) would result in a substantial lessening of competition in horizontal stabiliser trim actuators. Clearance was granted only in return for the undertaking to divest Safran’s North American actuation business, including sites in Mexico, California and Canada, to a pre-approved purchaser (Woodward).
In acquisitions in concentrated supply markets, prepare remedies including a buyer early – here the CMA required an upfront buyer.
- Authority / court
- Competition and Markets Authority (CMA)
- Area of law
- Competition law · Merger control
- Legal basis
- Enterprise Act 2002, s. 73 (Undertakings in lieu of reference)
- Action
- Order
- Status of proceedings
- final
- Sector
- Manufacturing and mechanical engineering
- Employees
- 10,000 or more
- Published
- 23 Jun 2025
- CMA case page: Safran / Collins merger inquiry Official register or notice
- CMA: Decision on acceptance of undertakings in lieu of reference (ME/7081/23) Decision of an authority
Checked against the official source on 25 Sep 2026 · Direct link
Report an error
30 Apr 2025 Luxembourg engineering firm: 7,000 EUR for incomplete record of processing activities €7,000
In an audit campaign on records of processing activities, the Commission nationale pour la protection des données (Luxembourg data protection authority, CNPD) found that an engineering and design consultancy (pseudonymised as ‘Société A’) had omitted mandatory information such as name and contact details, categories of data subjects and data, and retention periods. It imposed 7,000 EUR.
The record of processing activities is the first thing supervisory authorities request – it must be complete, including retention periods.
- Authority / court
- Commission nationale pour la protection des données (CNPD) – formation restreinte
- Area of law
- Data protection
- Legal basis
- DSGVO Art. 30 Abs. 1 lit. a, c, f
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Manufacturing and mechanical engineering
- CNPD – Délibération n° 3FR/2025 du 30 avril 2025 (Société A) Decision of an authority
Checked against the official source on 25 Sep 2026 · Direct link
Report an error
11 Feb 2025 KLUBB France SASVehicle body builder KLUBB France: CJIP over an ambulance contract in Algeria €558,024
Following a referral from the public prosecutor's office in Rennes, the PNF investigated bribery of foreign public officials in the performance of a contract for the supply of ambulances to Algeria. KLUBB France is paying a public interest fine of 558,024 EUR and is undergoing a three-year AFA compliance programme.
Medium-sized exporters are also in the spotlight: companies supplying foreign authorities need a robust anti-corruption programme under Sapin II (the French anti-corruption law).
Export contracts with state bodies
- 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); Bestechung ausländischer Amtsträger
- Action
- Fine
- Status of proceedings
- final
- Sector
- Manufacturing and mechanical engineering
- Employees
- 50 to 249
- Culpability
- intentional
- Liability of senior managers
- The CJIP does not address the criminal liability of natural persons.
- Published
- 11 Feb 2025
- Communiqué de presse du procureur de la République financier – CJIP KLUBB France Press release of an authority
- CJIP KLUBB France SAS (10.02.2025) Decision of an authority
Checked against the official source on 25 Sep 2026 · Direct link
Report an error
10 Feb 2025 Fatal pallet fall in warehouse: 100,000 EUR fine for industrial door manufacturer €100,000
In January 2023, in the warehouse of a manufacturer of industrial doors in Didam (anonymised in the judgment), a 792 kg pallet fell from an unstable stack four high onto a new employee, who died; the forklift used, fitted with fork extensions, had no CE marking of its own and was unsuitable for the load, the risk assessment was incomplete and the instruction of the victim, who did not speak Dutch, was inadequate. The Overijssel District Court (Rechtbank Overijssel, economic division) imposed 100,000 EUR (of which 25,000 EUR suspended) for intentional violations of the Dutch Working Conditions Act (Arbowet), plus 17,500 EUR in damages to the mother (ECLI:NL:RBOVE:2025:711).
Instruct employees in a language they understand – and draw consequences from earlier reportable accidents.
Instruction of employees who speak other languages; safe stacking
Missing or inadequate training played a role in the decision.
- Authority / court
- Rechtbank Overijssel (economische kamer)
- Area of law
- Health and safety and employment law · Workplace safety and accidents
- Legal basis
- Art. 32 Arbeidsomstandighedenwet i. V. m. Art. 5 Abs. 1, 8 Abs. 1 Arbeidsomstandighedenwet; Art. 3.17, 7.2 Abs. 1, 7.18 Abs. 2 Arbeidsomstandighedenbesluit
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Manufacturing and mechanical engineering
- Culpability
- intentional
- Mitigating circumstances
- No previous convictions of the company; part of the fine suspended.
- Rechtbank Overijssel, ECLI:NL:RBOVE:2025:711 vom 10.02.2025 Court decision
Checked against the official source on 25 Sep 2026 · Direct link
Report an error
17 Jan 2025 Haas Automation, Inc.Haas Automation: CNC parts and unlock codes for blocked Russian defence companies €2.47m
From December 2019 to March 2022, the Californian machine tool manufacturer indirectly supplied, via its dealer network, one CNC machine, 13 spare parts orders and seven unlock codes for machines of blocked Russian defence and energy companies. The US Treasury's Office of Foreign Assets Control (OFAC) imposed 1,044,781 USD (eight of the 21 violations egregious, no voluntary self-disclosure); at the same time, Haas paid 1.5 million USD to the US Commerce Department's Bureau of Industry and Security (BIS).
Spare parts and software unlock codes for machines already delivered are also services relevant to sanctions – end customers behind dealers must be known.
End-customer screening in dealer sales, software unlocks as a service
- Authority / court
- U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC); parallel U.S. Department of Commerce, Bureau of Industry and Security (BIS)
- Area of law
- Sanctions and export control · Breaches of sanctions and embargoes
- Legal basis
- Ukraine-/Russia-Related Sanctions Regulations (31 C.F.R. part 589; E.O. 13662); Export Administration Regulations
- Action
- Fine
- Status of proceedings
- final
- Sector
- Manufacturing and mechanical engineering
- Mitigating circumstances
- Substantial remedial measures and extensive cooperation
- Published
- 17 Jan 2025
Original amount 2,544,781 USD, converted at the ECB reference rate of 17 Jan 2025.
- OFAC Enforcement Release: Haas Automation, Inc. Settles with OFAC for $1,044,781 (17.01.2025) Decision of an authority
- OFAC – 2025 Enforcement Information Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
Report an error
22 Nov 2024 Sunseeker International LimitedSunseeker: 240,000 GBP fine and confiscation over Myanmar teak without due diligence €368,909
Between April 2021 and July 2022, the yacht builder imported eleven consignments of timber from the EU, including teak from Myanmar, without being able to demonstrate that the risk of illegal logging was negligible; its due diligence system was not maintained and documents were missing. Following a guilty plea, the Bournemouth Crown Court imposed a fine of 240,000 GBP and a confiscation of 66,950.64 GBP (plus costs of 51,619.96 GBP).
For timber from high-risk countries such as Myanmar, the risk can practically never be reduced to a negligible level – purchasing and design should switch to alternatives.
Due diligence for high-risk timber (Myanmar teak)
- Authority / court
- Bournemouth Crown Court (Anklage: Office for Product Safety and Standards (OPSS), Department for Business and Trade)
- Area of law
- Supply chain and human rights · Supply chain due diligence
- Legal basis
- Timber and Timber Products (Placing on the Market) Regulations 2013, Regulations 4(b), 4(c), 4(d)/4(e); Proceeds of Crime Act 2002
- Action
- Fine
- Status of proceedings
- final
- Sector
- Manufacturing and mechanical engineering
Original amount 306,950.64 GBP, converted at the ECB reference rate of 22 Nov 2024.
- OPSS enforcement actions 1 October 2024 to 31 March 2025 Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
Report an error
7 Nov 2024 Seven years' imprisonment: machine tools for sniper rifles to Russian arms manufacturer Custodial sentence
In 2015, despite the Russia embargo, the 56-year-old managing director of a Baden-Württemberg machine tool company and a Swiss holding company supplied six machine tools with accessories to a Russian arms manufacturer for the series production of sniper rifles, and concealed the recipient and intended use. The 2nd Criminal Division of the Stuttgart Higher Regional Court (Oberlandesgericht Stuttgart, Ref. 2 St 3 BJs 48/22) imposed an aggregate sentence of seven years' imprisonment; around 3 million EUR was confiscated from the holding company and 2.1 million EUR from the defendant (of which 674,000 EUR jointly and severally). Not final.
Embargo breaches with a defence connection are prosecuted as state security cases – even years later and with confiscation from foreign holding companies.
- Authority / court
- Oberlandesgericht Stuttgart, 2. Strafsenat (Az. 2 St 3 BJs 48/22)
- Area of law
- Sanctions and export control · Breaches of sanctions and embargoes
- Legal basis
- §§ 17, 18 Außenwirtschaftsgesetz i. V. m. Beschluss 2014/512/GASP und Verordnung (EU) Nr. 833/2014
- Action
- Custodial sentence
- Status of proceedings
- unknown
- Sector
- Manufacturing and mechanical engineering
- Culpability
- intentional
- Liability of senior managers
- Managing director personally sentenced to seven years' imprisonment.
- Published
- 7 Nov 2024
- OLG Stuttgart, 2. Strafsenat: Angeklagter wegen vier Verstößen gegen das AWG i. V. m. dem Russland-Embargo zu 7 Jahren verurteilt (07.11.2024) Court press release
- Generalbundesanwalt: Anklage wegen mutmaßlicher Verstöße gegen das Außenwirtschaftsgesetz erhoben (13.11.2023) Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
Report an error
11 Oct 2024 Moog Inc.Moog: SEC order over bribery of Indian public officials by a subsidiary €1.54m
From 2020 to 2022, employees of the Indian subsidiary of the aerospace and defence supplier bribed Indian public officials via agents and distributors, among other things to tailor tenders in Moog's favour; the payments were booked as business expenses. Payment of 504,926 USD in disgorgement, 78,889 USD in interest and a penalty of 1.1 million USD.
Even small foreign subsidiaries need effective controls over payments to distributors and agents – otherwise the listed parent company is liable under the books-and-records provisions.
Influencing tender conditions via distributors
- Authority / court
- U.S. Securities and Exchange Commission (SEC)
- Area of law
- Bribery and corruption · Bribery of public officials
- Legal basis
- FCPA Buchführungs- und interne Kontrollvorschriften (Sections 13(b)(2)(A)/(B) Exchange Act)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Manufacturing and mechanical engineering
- Culpability
- intentional
- Mitigating circumstances
- Cooperation (sharing of internal investigation findings) and remediation, including termination of employees and third parties.
- Published
- 11 Oct 2024
Original amount 1,683,815 USD, converted at the ECB reference rate of 11 Oct 2024.
- SEC Order In the Matter of Moog Inc., Release No. 101307 (11.10.2024) Decision of an authority
- SEC Enforcement Actions: FCPA Cases Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
Report an error
10 Sep 2024 Deere & CompanyDeere pays 9.9 million USD: Wirtgen Thailand bribed the air force and the highways authority €9m
From 2017 to 2020, the acquired subsidiary Wirtgen Thailand provided public officials, including officials of the Royal Thai Air Force and the Department of Highways, with cash, sham consultancy fees, luxurious "factory visit trips", meals and entertainment, and also engaged in commercial bribery. Deere is paying 4,343,401 USD in disgorgement, 1,086,954 USD in interest and a penalty of 4.5 million USD.
After acquisitions, integrate subsidiaries swiftly into the compliance programme and controls – otherwise old practices such as luxury trips for customers live on.
Travel, hospitality and entertainment for public officials
- Authority / court
- U.S. Securities and Exchange Commission (SEC)
- Area of law
- Bribery and corruption · Gifts, hospitality and benefits
- Legal basis
- FCPA Buchführungs- und interne Kontrollvorschriften (Sections 13(b)(2)(A)/(B) Exchange Act)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Manufacturing and mechanical engineering
- Employees
- 10,000 or more
- Culpability
- intentional
- Liability of senior managers
- According to the SEC, senior regional managers who have since left the company were involved (not named).
- Published
- 10 Sep 2024
Original amount 9,930,355 USD, converted at the ECB reference rate of 10 Sep 2024.
- SEC Order In the Matter of Deere & Company, Release No. 100984 (10.09.2024) Decision of an authority
- SEC Enforcement Actions: FCPA Cases Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
Report an error
1 Mar 2024 MTU Aero Engines AGMTU Aero Engines: inside information not disclosed without delay overturned
BaFin imposed a fine of 510,000 EUR on the engine manufacturer because it allegedly had not disclosed inside information without delay. Following an objection by the company, the Local Court of Frankfurt am Main (Amtsgericht) discontinued the proceedings on 21 January 2025 pursuant to Section 47 (2) OWiG (German Administrative Offences Act).
Document the ad hoc assessment in such a way that the company can later substantiate its decision on the timing and content of a disclosure.
Ad hoc disclosure: recognising inside information and disclosing it without delay
- Authority / court
- Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
- Area of law
- Capital markets and financial supervision · Disclosure and reporting obligations
- Legal basis
- Art. 17 Abs. 1 UAbs. 1 MAR
- Action
- Fine
- Status of proceedings
- overturned
- Sector
- Manufacturing and mechanical engineering
- Published
- 20 Mar 2024
Amount in EUR; no ECB reference rate is available for this currency.
- MTU Aero Engines AG: BaFin setzt Geldbuße fest Decision of an authority
- Bekanntmachung der BaFin zur MTU Aero Engines AG (Maßnahmenansicht mit Rechtskraftvermerk) Official register or notice
Checked against the official source on 25 Sep 2026 · Direct link
Report an error
7 Dec 2023 KION Group AGKION Group: ad hoc disclosure obligation breached, fine final €280,000
The intralogistics and forklift truck group had not disclosed inside information. BaFin imposed a fine of 280,000 EUR, which has been final since January 2024.
Escalate potential inside information to the ad hoc disclosure committee immediately, not at the next reporting date.
Ad hoc disclosure: recognising inside information and disclosing it without delay
- Authority / court
- Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
- Area of law
- Capital markets and financial supervision · Disclosure and reporting obligations
- Legal basis
- Art. 17 Abs. 1 UAbs. 1 MAR
- Action
- Fine
- Status of proceedings
- final
- Sector
- Manufacturing and mechanical engineering
- Published
- 21 Dec 2023
- KION Group AG: BaFin setzt Geldbuße fest Decision of an authority
- Bekanntmachung der BaFin zur KION Group AG (Maßnahmenansicht mit Rechtskraftvermerk) Official register or notice
Checked against the official source on 25 Sep 2026 · Direct link