Compliance Radar

Who was sanctioned, and for what?

Fines, court rulings and incidents from Europe, North America, Latin America, Asia-Pacific and Middle East: 1,929 cases from 40 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.

8cases from 1 jurisdiction
€11mTotal of monetary amounts (6 cases with an amount)
€4.98mLargest single case: JBJ Agropecuária Ltda., Prima Foods S.A.
€1.16mMedian per case with an amount

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When?

per quarter, by date of decision
Trend
PeriodCasesTotal
Q4 20230–
Q1 20240–
Q2 20240–
Q3 20240–
Q4 20240–
Q1 20250–
Q2 20251€3.44m
Q3 20250–
Q4 20252–
Q1 20261€4.98m
Q2 20262€2.31m
Q3 20262€237,188
Q4 20260–

8 cases

2 Sep 2026 Cervejaria Petrópolis S.A. (em recuperação judicial); Imcopa Importação, Exportação e Indústria de Óleos S.A.CADE fines Cervejaria Petrópolis for early closing of Imcopa takeover BrazilMerger control €231,813

The Tribunal of the Conselho Administrativo de Defesa Econômica (CADE, Brazilian competition authority) unanimously found that Cervejaria Petrópolis had taken control of the oil producer Imcopa before the legally required notification (gun jumping) and imposed a fine of 1,382,418.22 BRL. According to the investigation, the acquisition was completed on 19 March 2024 but notified only on 9 April 2024; CADE itself cleared the transaction without conditions in April 2024. The argument that the change of control resulted from court decisions in the judicial reorganisation proceedings (recuperação judicial) did not persuade the authority. The amount and the facts have not been confirmed against the primary source.

What organisations can take from it

Acquisitions in a restructuring or insolvency context, too, may be completed only after notification and clearance.

Relevance to training and awareness

Standstill obligation before clearance in merger control (gun jumping)

Authority / court
Conselho Administrativo de Defesa Econômica (CADE), Tribunal Administrativo
Area of law
Competition law · Merger control
Legal basis
Art. 88 § 3 Lei nº 12.529/2011 (Lei de Defesa da Concorrência)
Action
Fine
Status of proceedings
unknown
Sector
Food and agriculture
Published
8 Sep 2026

Original amount 1,382,418.22 BRL, converted at the ECB reference rate of 2 Sep 2026.

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

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23 Jul 2026 Arla Foods Ingredientes Comércio de Produtos Alimentícios Unipessoal Ltda.Arla Foods Ingredientes: leniency agreement after self-report for BRL 31,056.36 BrazilBribery and corruption €5,375

Arla Foods Ingredientes Comércio de Produtos Alimentícios Unipessoal Ltda. 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) concerning violations of the Anti-Corruption Law described in an unpublished annex; it had been the first to come forward, in October 2022. The alleged fine of BRL 31,056.36 derives from a preliminary fine of BRL 93,150.45, based on 2021 gross revenue of BRL 6,210,029.68, reduced by 66.66% for self-reporting, degree of cooperation and payment terms.

What organisations can take from it

Self-reporting, full cooperation and the payment terms can together cut a fine under Brazil's Anti-Corruption Law by two thirds in a leniency agreement.

Relevance to training and awareness

Self-reporting and cooperation where corruption is suspected

Authority / court
Controladoria-Geral da União (CGU) und Advocacia-Geral da União (AGU)
Area of law
Bribery and corruption
Legal basis
Lei nº 12.846/2013, Art. 16 und 17; Decreto nº 11.129/2022, Art. 22, 23 und 47; Lei nº 8.429/1992
Action
Fine
Status of proceedings
final
Sector
Food and agriculture
Mitigating circumstances
Total reduction of 66.66% (22.22% each for self-reporting, degree of cooperation and payment terms); compensation for losses, cooperation and voluntary admission also counted as mitigating factors in the calculation.
Liability of senior managers
As an aggravating factor, the CGU found that management tolerated or was aware of the acts (3% uplift).

Original amount 31,056.36 BRL, converted at the ECB reference rate of 23 Jul 2026.

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

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27 May 2026 Frigorífico Cason Ltda., ASM Comércio de Subprodutos de Origem Animal Ltda., ASM Comércio e Coleta de Ossos Ltda.CADE: buyer cartel for animal by-products in Rio Grande do Sul – BRL 6.4m BrazilCartels and collusion €1.09m

The CADE Tribunal convicted three companies of a buyer cartel in the purchase of animal residues in Rio Grande do Sul: according to CADE, rendering plants and haulage companies divided collection points among themselves, exchanged sensitive information and obstructed competitors outside the arrangement. Frigorífico Cason received 5,937,915.73 BRL and the two ASM companies jointly 455,419.65 BRL (6,393,335.38 BRL in total); proceedings against several other parties were closed because settlements had been fulfilled or for lack of evidence. The amount and the facts have not been confirmed against the primary source.

What organisations can take from it

Buyers, too, must not coordinate the allocation of suppliers or collection areas; buyer cartels are prohibited just like seller cartels.

Relevance to training and awareness

Buyer cartels and allocation of supply or collection areas

Authority / court
Conselho Administrativo de Defesa Econômica (CADE), Tribunal Administrativo
Area of law
Competition law · Cartels and collusion
Legal basis
Lei nº 12.529/2011
Action
Fine
Status of proceedings
unknown
Sector
Food and agriculture
Liability of senior managers
Measures against individuals are not set out here.
Published
29 May 2026

Original amount 6,393,335.38 BRL, converted at the ECB reference rate of 27 May 2026.

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

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24 Apr 2026 Colônia dos Pescadores Z-12 do Médio Rio DoceFishers' colony Z-12: BRL 7.18m CGU fine over fraud involving Renova compensation BrazilBribery and corruption €1.23m

The CGU imposed on the Colônia dos Pescadores Z-12 do Médio Rio Doce a fine of BRL 7,180,921.47 and extraordinary publication of the decision. Acting together with others, the association had falsified its members' applications for entry in the fishing register (RGP) and backdated records and had interfered with the federal fisheries office in Espírito Santo, so that false data found their way into official documents and compensation from the Fundação Renova, together with lawyers' fees, was paid out without entitlement (Art. 5 II, III and V Lei 12.846/2013).

Relevance to training and awareness

Falsified documents submitted to authorities to obtain compensation

Authority / court
Controladoria-Geral da União (CGU)
Area of law
Bribery and corruption
Legal basis
Lei 12.846/2013, Art. 5 II, III und V, Art. 6 I und II, Art. 14; Decreto 11.129/2022, Arts. 19, 22 und 23
Action
Fine
Status of proceedings
unknown
Sector
Food and agriculture
Liability of senior managers
Measures against individuals are not set out here.
Published
5 May 2026

Original amount 7,180,921.47 BRL, converted at the ECB reference rate of 24 Apr 2026.

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

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26 Jan 2026 JBJ Agropecuária Ltda., Prima Foods S.A.JBJ Agropecuária and Prima Foods: BRL 31.16m in fines under leniency agreement BrazilBribery of public officials €4.98m

JBJ Agropecuária Ltda. and Prima Foods S.A. acknowledged, in a leniency agreement with the CGU and the AGU, that they had paid an economic advantage to a public official whose action or omission was in their interest (Art. 5 I Lei 12.846/2013). After a 66.6% reduction they allegedly pay fines totalling BRL 31,156,767.70 in three annual instalments and are jointly and severally liable for them. Payments under an agreement on the same facts with the Federal Public Prosecutor's Office (MPF) are credited.

What organisations can take from it

Parallel agreements with prosecutors and oversight bodies can be coordinated – double payments are credited, but the liability remains.

Relevance to training and awareness

Payment to a public official to influence official action

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 12.846/2013, Art. 5 I, Art. 6 I, Arts. 16 und 17; Decreto 11.129/2022
Action
Fine
Status of proceedings
final
Sector
Food and agriculture
Mitigating circumstances
For JBJ, credit was given for restitution or compensation (1%), cooperation (1.5%), voluntary admission (2%) and an applied compliance programme (2.5%); overall a 66.6% reduction on the full fine of BRL 93,283,735.64.
Liability of senior managers
For JBJ, tolerance or knowledge by management (3%) and the concurrence of several offences (3%) were aggravating factors.

Original amount 31,156,767.7 BRL, converted at the ECB reference rate of 26 Jan 2026.

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

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22 Dec 2025 Renuka Vale do Ivaí S.A. (em recuperação judicial)Renuka Vale do Ivaí: sugar mill placed on the ‘Lista Suja’ over slave-like labour BrazilForced and child labour Other

The Ministério do Trabalho e Emprego (MTE, Ministry of Labour and Employment) entered the sugar mill Renuka Vale do Ivaí S.A. (in judicial reorganisation) in the register of employers that have subjected workers to conditions analogous to slavery (Cadastro de Empregadores, the ‘Lista Suja’). The entry is based on a 2025 labour inspection at the sugar cane mill in São Pedro do Ivaí (Paraná) involving 57 workers; the final administrative decision was taken on 22 December 2025 and the entry was made in the update of 6 April 2026.

What organisations can take from it

Sugar industry companies must continuously check working conditions at their sites, because an entry on the ‘Lista Suja’ is published by name.

Relevance to training and awareness

Recognising and preventing slave-like working conditions

Authority / court
Ministério do Trabalho e Emprego (MTE), Inspeção do Trabalho
Area of law
Supply chain and human rights · Forced and child labour
Legal basis
Portaria Interministerial MTE/MDHC/MIR nº 18/2024 (Cadastro de Empregadores)
Action
Other
Status of proceedings
final
Sector
Food and agriculture
Published
6 Apr 2026

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

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22 Oct 2025 Joca Participações S/AJoca Participações: ‘Lista Suja’ entry over 25 workers on Fazenda Aroeira BrazilForced and child labour Other

The MTE (Ministry of Labour and Employment) entered Joca Participações S/A on 6 April 2026 in the register of employers that have kept workers in conditions akin to slavery (the ‘Lista Suja’). The entry is based on a labour inspection in 2025 at Fazenda Aroeira in Getulina (SP) involving 25 affected workers; the administrative finding was issued on 22 October 2025.

What organisations can take from it

Investment companies running their own farming operations also bear responsibility as employers for the workers on site.

Relevance to training and awareness

Conditions akin to slavery in agriculture

Authority / court
Ministério do Trabalho e Emprego (MTE), Inspeção do Trabalho
Area of law
Supply chain and human rights · Forced and child labour
Legal basis
Portaria Interministerial MTE/MDHC/MIR nº 18/2024, Art. 2
Action
Other
Status of proceedings
unknown
Sector
Food and agriculture
Published
6 Apr 2026

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

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5 May 2025 Minerva S.A.Minerva: BRL 22m fine under leniency agreement over advantages for public officials BrazilBribery of public officials €3.44m

Minerva S.A. acknowledged, in a leniency agreement with the CGU and the AGU, that it had paid economic advantages to public officials whose action or omission was in the company's interest. The full fine under Art. 6 I Lei 12.846/2013 of BRL 51,376,161.22 was reduced by 57.1% to BRL 22,040,373.16 (indexed to IPCA up to March 2025) and is allegedly payable to the Union. The amount and the facts have not been confirmed against the primary source.

What organisations can take from it

A working compliance programme and early cooperation noticeably reduce the fine, but do not cancel out the effect of management responsibility.

Relevance to training and awareness

Payments to public officials to influence official action

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 12.846/2013, Art. 6 I, Arts. 16 und 17; Lei 8.429/1992, Art. 12; Decreto 11.129/2022
Action
Fine
Status of proceedings
final
Sector
Food and agriculture
Mitigating circumstances
Credit was given for returning the advantage (1%), cooperation (1%), voluntary admission (1.5%) and an applied compliance programme (2.1%).
Liability of senior managers
Tolerance or knowledge by management (3%) and the concurrence of several offences (3%) were aggravating factors.

Original amount 22,040,373.16 BRL, converted at the ECB reference rate of 5 May 2025.

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

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