Who was sanctioned, and for what?

The U.S. Forced Labor Enforcement Task Force (FLETF) added the cotton and textile producer to the Uyghur Forced Labor Prevention Act (UFLPA) Entity List because it sources cotton from Xinjiang. The company's goods are therefore presumed to have been produced with forced labour on import into the US unless the importer rebuts this.

Authority / court

U.S. Department of Homeland Security (Forced Labor Enforcement Task Force)

Area of law

Supply chain and human rights · Forced and child labour

Legal basis

Uyghur Forced Labor Prevention Act, Section 2(d)(2)(B)(v)

Action

Order

Status of proceedings

unknown

Sector

Other

Published

3 Aug 2026

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

After around one million gallons of sulphuric acid were released at the BWC Terminals site in Channelview (Texas) in December 2025, OSHA proposed penalties totalling 3,520,703 USD against three employers. Staffing contractor One Way Environmental Services accounts for 3,045,452 USD for 18 violations classed as wilful and egregious and five as serious, because it sent workers to the clean-up without adequate training, respirator fit tests and safety measures; the hazardous waste contractor Coastal Environmental Solutions faces 392,501 USD and BWC Terminals, which had mixed fresh and spent acid despite warnings, 82,750 USD. The authority allegedly made the findings set out here; this account is not based on a final judgment. The decision is not final.

Authority / court

U.S. Department of Labor – Occupational Safety and Health Administration (OSHA)

Area of law

Health and safety and employment law · Workplace safety and accidents

Legal basis

Occupational Safety and Health Act (u. a. Vorschriften zu Gefahrstoffeinsätzen und Notfallmaßnahmen sowie Atemschutz)

Action

Fine

Status of proceedings

not yet final

Sector

Other

Published

26 Jun 2026

Original amount 3,520,703 USD, converted at the ECB reference rate of 26 Jun 2026.

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

U.S. Customs and Border Protection (CBP) issued a Withhold Release Order: clothing from Needle Craft Ltd.; Casual Wear Apparel LLC (Jordan) is being detained at all US ports of entry because there are indications of forced labour (ILO indicators including physical and sexual violence, retention of identity documents, restriction of movement and withholding of wages). These are two parallel orders against both manufacturers.

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

Other

Published

23 Jun 2026

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

According to the Attorney General's office, the fitness franchisor stated three to six months until studio opening in the disclosure documents filed in New York, although it took more than 13 months on average and its own SEC reports showed longer periods. The Assurance of Discontinuance requires 3,971,250 USD: 3 million USD for 70 harmed franchisees (of which 300,000 USD is a civil penalty) and 971,250 USD in fee refunds to 25 franchisees who never opened. The authority allegedly made the findings set out here; this account is not based on a final judgment.

Authority / court

Office of the New York State Attorney General (Investor Protection Bureau, Franchise Section)

Area of law

Consumer protection and online retail

Legal basis

New York Franchise Sales Act (General Business Law §§ 680 ff., insb. § 687); Executive Law § 63(12)

Action

Disgorgement of profits

Status of proceedings

final

Sector

Other

Published

9 Jun 2026

Original amount 3,971,250 USD, converted at the ECB reference rate of 9 Jun 2026.

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

Consulting firm FTI Consulting, Inc. of Washington, D.C. is paying USD 1,050,000 under a settlement with OFAC for apparent violations of the Russia financial sector sanctions. According to OFAC's findings, between April 2019 and May 2021 FTI indirectly extended prohibited debt on six occasions to a Russian state-owned bank subject to Directive 1 under Executive Order 13662: invoices remained unpaid beyond the permitted 14 days or were paid long afterwards while FTI continued to provide services. OFAC treated the apparent violations as non-egregious and not voluntarily self-disclosed; the base penalty was USD 525,000. The settlement amount is above the base penalty; OFAC cited in particular the anticipated impact on future compliance by similarly situated firms. Source: U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC), enforcement release "FTI Consulting, Inc., a Global Business Advisory Firm, Settles with OFAC for $1,050,000 Related to Apparent Violations of Dealing in Prohibited Debt of Sanctioned Russian Bank", 1 June 2026, https://ofac.treasury.gov/media/935651/download?inline; summarised in our own words.

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

Ukraine-/Russia-Related Sanctions Regulations, 31 C.F.R. §§ 589.202, 589.213 i. V. m. Directive 1 zu E.O. 13662 (sechs mutmaßliche Verstöße); Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A

Action

Fine

Status of proceedings

final

Sector

Other

Published

1 Jun 2026

Original amount 1,050,000 USD, converted at the ECB reference rate of 1 Jun 2026.

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

School and sports academy IMG Academy, LLC of Bradenton, Florida, is paying USD 1,720,000 under a settlement with OFAC for apparent violations of the counternarcotics sanctions. According to OFAC's findings, between 2019 and 2025 IMG Academy entered into tuition agreements for the children of two individuals on the SDN List because of their ties to a sanctioned Mexican drug cartel and processed the related payments; 89 dealings were involved in total. OFAC treated the apparent violations as non-egregious and not voluntarily self-disclosed because an investigation was already under way when the academy reported them; the settlement amount equals the base penalty. Source: U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC), enforcement release "IMG Academy, LLC Settles with OFAC for $1.7 Million Related to Apparent Violations of Counternarcotics Sanctions", 12 February 2026, https://ofac.treasury.gov/media/935006/download?inline; summarised in our own words.

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

Foreign Narcotics Kingpin Sanctions Regulations, 31 C.F.R. § 598.202 (89 mutmaßliche Verstöße); Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A

Action

Fine

Status of proceedings

final

Sector

Other

Published

12 Feb 2026

Original amount 1,720,000 USD, converted at the ECB reference rate of 12 Feb 2026.

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

Without registering as a data broker, the Texas reseller traded in the names and contact details of millions of people, sorted by illnesses such as Alzheimer's or addiction, by age, presumed ethnicity and political views. In addition to the fine, the California Privacy Protection Agency (CPPA) requires it to stop selling data on all Californians.

Authority / court

California Privacy Protection Agency (CPPA)

Area of law

Data protection · Marketing and consent

Legal basis

California Delete Act (Registrierungspflicht für Datenhändler)

Action

Fine

Status of proceedings

final

Sector

Other

Published

8 Jan 2026

Original amount 45,000 USD, converted at the ECB reference rate of 30 Dec 2025.

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

On 13 November 2025, the Nevada Gaming Control Board (NGCB) filed a disciplinary complaint for unsuitable methods of operation in connection with an illegal bookmaker and at the same time concluded a settlement of 7.8 million USD with conditions attached to the gaming licences. The conditions relate primarily to improving the AML programme and to additional training and awareness-raising for employees; the Nevada Gaming Commission (NGC) adopted the settlement as its order on 20 November 2025 (Case No. 25-03).

Authority / court

Nevada Gaming Commission (NGC) auf Beschwerde des Nevada Gaming Control Board (NGCB)

Area of law

Money laundering and terrorist financing · Customer due diligence

Legal basis

Glücksspielrecht Nevada (unsuitable methods of operation)

Action

Fine

Status of proceedings

final

Sector

Other

Employees

10,000 or more

Mitigating circumstances

Numerous remedial measures already implemented

Published

13 Nov 2025

Original amount 7,800,000 USD, converted at the ECB reference rate of 20 Nov 2025.

Checked against the official source on 27 Sep 2026 · Version 2 · Direct link

U.S. Customs and Border Protection (CBP) issued a Withhold Release Order: clothing and textiles from Firemount Group Ltd. (Mauritius) are being detained at all US ports of entry because there are indications of forced labour (ILO indicators including abuse of vulnerability, debt bondage, deception, and intimidation and threats).

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

Other

Published

18 Nov 2025

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

More than 90 cleaners in industrial, laboratory and healthcare facilities often worked beyond scheduled hours without overtime pay, received no compensation for split shifts and travel time and were unable to take breaks because of excessive workloads. A web of companies concealed the employer; the Notice of Final Findings of 21 October 2025 established 438,204 USD, with OptumCare jointly liable as the client.

Authority / court

California Labor Commissioner's Office (Division of Labor Standards Enforcement)

Area of law

Health and safety and employment law · Working time

Legal basis

California Labor Code § 2810.3; Overtime, Split Shift, Meal and Rest Periods, Mindestlohn

Action

Other

Status of proceedings

unknown

Sector

Other

Liability of senior managers

Measures against individuals are not reported here.

Published

24 Nov 2025

Original amount 438,204 USD, converted at the ECB reference rate of 21 Oct 2025.

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

Under a court settlement (Stipulation and Order of Settlement) with the US Department of Justice and the EPA, Stericycle will pay a civil penalty of 9,500,000 USD for RCRA violations in its hazardous waste transport, storage and disposal business, which it operated until April 2020. The company lost track of shipments, delivered waste without the required manifests or to facilities not chosen by the customer, stored it too long at transfer facilities and failed to submit thousands of manifests to the EPA's e-Manifest system on time. According to the EPA, it is the first judicial action to enforce the e-Manifest requirements. The authority allegedly made the findings set out here; this account is not based on a final judgment.

Authority / court

U.S. Environmental Protection Agency (EPA) / U.S. Department of Justice (U.S. District Court, Southern District of New York)

Area of law

Environment and sustainability · Waste and hazardous substances

Legal basis

Resource Conservation and Recovery Act (RCRA), 42 U.S.C. § 6901 ff., e-Manifest-Vorschriften

Action

Fine

Status of proceedings

unknown

Sector

Other

Published

17 Jan 2025

Original amount 9,500,000 USD, converted at the ECB reference rate of 17 Jan 2025.

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

According to the Federal Trade Commission (FTC, the US consumer protection authority), three attacks between 2014 and 2020 affected more than 344 million guests worldwide, including 5.25 million unencrypted passport numbers; one intrusion went undetected for 14 months. The FTC alleges inadequate password, access, firewall and segmentation controls, failure to patch, insufficient logging and too little MFA; the order finalised in December 2024 requires a security programme with annual certification to the FTC for 20 years, independent assessments every two years, data minimisation and a deletion option for US customers. In parallel, Marriott pays 52 million USD to 49 states and Washington, D.C.

Authority / court

Federal Trade Commission (FTC)

Area of law

Information security and cyber · Security measures and risk management

Legal basis

Section 5 FTC Act

Action

Order

Status of proceedings

final

Sector

Other

Employees

10,000 or more

Published

20 Dec 2024

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

Californian musical instrument manufacturer Córdoba Music Group LLC is paying USD 41,591 under a settlement with OFAC for apparent violations of the Iran sanctions. According to OFAC's findings, between November 2019 and March 2022 the company made nine shipments of instruments and accessories worth USD 118,831 to a trading company in Dubai, knowing that the goods were destined for an Iranian distributor. According to OFAC, the company apparently did not realise, partly owing to a lack of compliance training, that indirect exports to Iran were prohibited. This came to light after the company was acquired by a new owner. OFAC treated the apparent violations as non-egregious and voluntarily self-disclosed; the base penalty was USD 59,416. Source: U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC), enforcement release "Córdoba Music Group LLC Settles with OFAC for $41,591 Related to Apparent Violations of the Iranian Transactions and Sanctions Regulations", 18 December 2024, https://ofac.treasury.gov/media/933726/download?inline; summarised in our own words.

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, 31 C.F.R. § 560.204(a) (neun Lieferungen); Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A

Action

Fine

Status of proceedings

final

Sector

Other

Published

18 Dec 2024

Original amount 41,591 USD, converted at the ECB reference rate of 18 Dec 2024.

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

The South African subsidiary of McKinsey & Company entered into a three-year DPA with a penalty of USD 122,850,000; up to half is credited against payments to South African authorities. According to the Department, between at least 2012 and 2016 it obtained confidential information from two South African state-owned companies (logistics and energy) on consulting contracts and bid knowing that South African partner firms would pass part of their fees on to officials as bribes. According to the Department, the profit from the scheme was about USD 85 million.

Authority / court

U.S. Department of Justice (Criminal Division, Fraud Section; USAO Southern District of New York)

Area of law

Bribery and corruption · Bribery of public officials

Legal basis

Foreign Corrupt Practices Act (FCPA): Verschwörung zum Verstoß gegen die Anti-Bribery-Vorschriften (Criminal Information, Southern District of New York)

Action

Fine

Status of proceedings

unknown

Sector

Other

Mitigating circumstances

Credit was given for immediate, proactive cooperation, reporting of discovered attempts to delete records, personnel consequences, additional anti-corruption training in Africa and a temporary halt to work for state-owned enterprises.

Liability of senior managers

Measures against individuals are not reported here.

Published

5 Dec 2024

Original amount 122,850,000 USD, converted at the ECB reference rate of 5 Dec 2024.

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

The company entered into a three-year DPA; under the guidelines USD 54 million would have been appropriate, but because of a demonstrated inability to pay a penalty of USD 10 million was agreed, of which up to USD 4 million is credited against the SEC civil penalty. From 2017 to 2019 the company, then trading as 500.com, agreed to pay about USD 1.9 million to consultants, intended to reach Japanese officials as cash, travel, entertainment and gifts, in order to win an integrated resort bid in Japan; the payments were booked as consultancy fees under sham contracts. The authority allegedly made the findings set out here; this account is not based on a final judgment.

Authority / court

U.S. Department of Justice (Criminal Division, Fraud Section; USAO District of New Jersey)

Area of law

Bribery and corruption · Bribery of public officials

Legal basis

Foreign Corrupt Practices Act (FCPA): Verschwörung zum Verstoß gegen die Anti-Bribery- und Books-and-Records-Vorschriften sowie Verstoß gegen die Books-and-Records-Vorschriften (Criminal Information, District of New Jersey)

Action

Fine

Status of proceedings

final

Sector

Other

Mitigating circumstances

The penalty was capped at USD 10 million because of the company's financial condition; limited, reactive cooperation and remediation were credited (10% reduction off the bottom of the guidelines range).

Liability of senior managers

Measures against individuals are not set out here.

Published

18 Nov 2024

Original amount 10,000,000 USD, converted at the ECB reference rate of 18 Nov 2024.

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

In December 2022 an attacker used an employee's stolen credentials to break into the systems of the cinema operator National Amusements because multi-factor authentication was not enforced for all access routes; data such as social security, passport and account numbers of 82,128 people was affected – according to the company, current and former employees and contractors – of whom 23,365 were in New York, and some of the social security numbers were stored unencrypted. Those affected were only notified on 18 December 2023, more than a year after the incident. Under the Assurance of Discontinuance with the New York Attorney General's office, the company pays 250,000 USD and must introduce, among other things, encryption, password rules, vulnerability testing and an incident response plan. The authority allegedly made the findings set out here; this account is not based on a final judgment.

Authority / court

Office of the New York State Attorney General (Bureau of Internet & Technology)

Area of law

Data protection · Employee data

Legal basis

New York Executive Law § 63(12); New York General Business Law § 899-aa (Benachrichtigung bei Datenpannen) und § 899-bb (SHIELD Act, Datensicherheit)

Action

Fine

Status of proceedings

final

Sector

Other

Published

15 Nov 2024

Original amount 250,000 USD, converted at the ECB reference rate of 13 Nov 2024.

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

The US Financial Crimes Enforcement Network (FinCEN) imposed 900,000 USD on the Californian card club, which admitted wilful infringements over more than four and a half years: no effective AML programme, missing currency transaction reports (CTR) and suspicious activity reports (SAR), and record-keeping deficiencies. The infringements stemmed from decisions by management.

Authority / court

Financial Crimes Enforcement Network (FinCEN)

Area of law

Money laundering and terrorist financing · Suspicious activity reports

Legal basis

Bank Secrecy Act (BSA) und Durchführungsbestimmungen

Action

Fine

Status of proceedings

final

Sector

Other

Culpability

intentional

Liability of senior managers

According to FinCEN, the infringements were based on decisions by management

Published

23 Oct 2024

Original amount 900,000 USD, converted at the ECB reference rate of 22 Oct 2024.

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

Vietnamese holding company Vietnam Beverage Company Limited is paying USD 860,000 under a settlement with OFAC on behalf of two subsidiaries for apparent violations of the North Korea sanctions. According to OFAC's findings, between April 2016 and October 2018 the beverage subsidiaries received payments of around USD 1,141,547 through US financial institutions on 43 occasions for the sale of alcoholic beverages to North Korea, thereby causing those institutions to export financial services to North Korea. OFAC treated the apparent violations as non-egregious and not voluntarily self-disclosed but credited its cooperation and its proactive notification of internal findings; the base penalty was USD 1,720,000. Source: U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC), enforcement release "Vietnam Beverage Company Limited settles with OFAC for $860,000 for Apparent Violations of the North Korea Sanctions Regulations", 17 October 2024, https://ofac.treasury.gov/media/933501/download?inline; summarised in our own words.

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

North Korea Sanctions Regulations, 31 C.F.R. § 510.212 (43 mutmaßliche Verstöße); Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A

Action

Fine

Status of proceedings

final

Sector

Other

Published

17 Oct 2024

Original amount 860,000 USD, converted at the ECB reference rate of 17 Oct 2024.

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

A London-based tobacco group is paying USD 508,612,492, the statutory maximum, under a settlement with OFAC for apparent violations of the North Korea sanctions and the weapons of mass destruction proliferators sanctions. According to OFAC's findings, the group entered into a conspiracy to supply tobacco products to North Korea and to route payments for them through the US financial system; around USD 251.6 million flowed in this way between 2009 and 2016. In addition, its Singapore subsidiary received US dollar payments via US banks for cigarette sales to the North Korean embassy in Singapore. As a result, US banks processed payments involving blocked North Korean banks. OFAC treated the apparent violations as egregious and not voluntarily self-disclosed. The settlement was concluded alongside a resolution with the DOJ; USD 503,263,807 is deemed satisfied by the payment there and USD 5,348,685 is payable to the Treasury. Summarised in our own words.

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

Weapons of Mass Destruction Proliferators Sanctions Regulations, 31 C.F.R. § 544.205(b) (ein mutmaßlicher Verstoß); North Korea Sanctions Regulations, 31 C.F.R. § 510.212 (15 mutmaßliche Verstöße); Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A

Action

Fine

Status of proceedings

final

Sector

Other

Published

25 Apr 2023

Original amount 508,612,492 USD, converted at the ECB reference rate of 17 Apr 2023.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 17 Apr 2025 · Direct link

New York had sued the e-cigarette maker in 2019 over youth-oriented advertising, misleading claims about nicotine content and safety, and sales to minors; together with California, the Attorney General's office led a settlement of six states and the District of Columbia. The maker pays a total of 462 million USD in instalments (112,749,633.37 USD of it to New York) and subjects its sales and advertising to strict restrictions. Measures against individuals are not set out here. The authority allegedly made the findings set out here; this account is not based on a final judgment.

Authority / court

Office of the New York State Attorney General (gemeinsam mit dem Attorney General of California; Einigung von sechs Bundesstaaten und D.C.)

Area of law

Consumer protection and online retail · Misleading advertising and pricing

Legal basis

New York General Business Law §§ 349, 350; Executive Law § 63(12); Public Nuisance (Common Law)

Action

Other

Status of proceedings

unknown

Sector

Other

Liability of senior managers

Measures against individuals are not set out here.

Published

12 Apr 2023

Original amount 462,000,000 USD, converted at the ECB reference rate of 12 Apr 2023.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 12 Apr 2025 · Direct link