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.

22cases from 1 jurisdiction
€1.84bnTotal of monetary amounts (14 cases with an amount)
€1.19bnLargest single case: Google LLC
€19.3mMedian per case with an amount

Click a bar to drill down one level.

When?

per year, by date of decision
Trend
PeriodCasesTotal
20221€23.8m
20233€277.1m
20248€122.6m
20258€1.42bn
20262–

22 cases

25 Jun 2026 Kochava Inc. und Collective Data Solutions, LLCKochava: court order ends FTC lawsuit over trade in location data USAData subject rights and transparency Order

After almost four years of litigation, the federal district court for Idaho entered an order agreed between the FTC and the data broker Kochava. The FTC had alleged that Kochava sold precise location data from hundreds of millions of mobile devices without the knowledge and consent of the people concerned, revealing, for example, visits to health facilities and places of worship. Kochava and its subsidiary Collective Data Solutions, which has taken over the data broker business, may only share sensitive location data with affirmative consent and for services requested by the consumer, and must introduce, among other things, a sensitive-locations programme, checks on their data suppliers, disclosure of recipients and retention limits; no payment is provided for. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

Anyone who buys or passes on location data must verify consent at the source and consistently filter out sensitive locations.

Relevance to training and awareness

Location data as sensitive data; due diligence when buying and reselling data

Authority / court
U.S. District Court for the District of Idaho auf Klage der Federal Trade Commission (FTC)
Area of law
Data protection · Data subject rights and transparency
Legal basis
Section 5 FTC Act, 15 U.S.C. § 45 (unlautere Praktiken); Verfahren nach Section 13(b), 15 U.S.C. § 53(b)
Action
Order
Status of proceedings
final
Sector
Telecoms, IT and software
Published
26 Jun 2026

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

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5 Jun 2026 Illuminate Education Inc.FTC: final order against education software provider Illuminate after data leak affecting 10.1 million students USAData breaches and data security Order

According to the complaint by the US Federal Trade Commission (FTC), Illuminate promised schools data security but did not adequately protect its cloud databases, even though a service provider had pointed out vulnerabilities almost two years earlier; a hacker accessed data on 10.1 million students, including health information. The order requires an information security programme, data minimisation and a public deletion schedule, and prohibits misrepresentations about security and notification deadlines.

What organisations can take from it

Do not leave known vulnerabilities unaddressed for years – security promises to customers are measured as binding commitments.

Authority / court
Federal Trade Commission (FTC)
Area of law
Data protection · Data breaches and data security
Legal basis
FTC Act (Verbot unlauterer und irreführender Praktiken)
Action
Order
Status of proceedings
final
Sector
Telecoms, IT and software
Culpability
negligent
Published
5 Jun 2026

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

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12 Nov 2025 Comunicaciones Celulares S.A. (TIGO Guatemala)TIGO Guatemala pays more than 118 million USD for bribing members of Congress USABribery of public officials €102.1m

From 2012 to 2018, the Guatemalan mobile network operator made monthly cash payments to members of Congress or their security staff in order to obtain legislative support; part of the funds came from laundered drug money. Two-year Deferred Prosecution Agreement with a criminal penalty of 60 million USD and administrative forfeiture of 58,198,343 USD.

What organisations can take from it

In joint ventures with local partners, the parent company needs genuine control over cash flows and contacts with public officials – an early voluntary self-disclosure is no substitute for a full investigation.

Relevance to training and awareness

Bribery of public officials, cash payments, integrity of co-shareholders

Authority / court
U.S. Department of Justice (Criminal Division, Fraud Section; USAO Southern District of Florida)
Area of law
Bribery and corruption · Bribery of public officials
Legal basis
FCPA, 15 U.S.C. § 78dd-3 (Verschwörung, 18 U.S.C. § 371); Deferred Prosecution Agreement
Action
Fine
Status of proceedings
final
Sector
Telecoms, IT and software
Culpability
intentional
Mitigating circumstances
Voluntary self-disclosure by the parent company Millicom in 2015; subsequently extensive cooperation and remediation (including dismissals of staff and an 800 % increase in compliance personnel).
Published
12 Dec 2025

Original amount 118,198,343 USD, converted at the ECB reference rate of 12 Nov 2025.

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

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31 Oct 2025 Google LLCTexas: Google pays $1.375 billion over location, incognito and biometric data USA, TXCookies and tracking €1.19bn

Texas, represented by the Office of the Attorney General, had sued Google for unlawfully collecting location data, activity in incognito mode and biometric identifiers. Google signed a settlement of $1.375 billion, concluding two sets of proceedings.

What organisations can take from it

Settings such as location history or incognito mode must deliver what they promise users – otherwise billion-dollar risks loom, even at the level of individual US states.

Authority / court
Office of the Attorney General of Texas
Area of law
Data protection · Cookies and tracking
Action
Other
Status of proceedings
final
Sector
Telecoms, IT and software
Employees
10,000 or more
Published
31 Oct 2025

Original amount 1,375,000,000 USD, converted at the ECB reference rate of 31 Oct 2025.

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

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18 Sep 2025 Chegg Inc.Chegg pays 7.5 million USD in FTC settlement over allegations of obstructed subscription cancellation USAInformation duties in online retail €6.35m

According to the FTC complaint, the education provider hid the cancellation option for its automatically renewing subscriptions on its website and, since October 2020, continued to charge almost 200,000 customers even after they had cancelled. Under the settlement, Chegg is paying 7.5 million USD for refunds and must offer simple cancellation.

What organisations can take from it

Cancellations received must be reliably implemented in the systems – continuing to charge customers is a separate violation.

Relevance to training and awareness

Cancellation processes and customer service for subscriptions

Authority / court
Federal Trade Commission (FTC)
Area of law
Consumer protection and online retail · Information duties in online retail
Legal basis
Restore Online Shoppers' Confidence Act (ROSCA); Section 5 FTC Act
Action
Disgorgement of profits
Status of proceedings
final
Sector
Telecoms, IT and software
Repeat case
yes
Published
15 Sep 2025

Original amount 7,500,000 USD, converted at the ECB reference rate of 18 Sep 2025.

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

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28 Jul 2025 Cadence Design Systems Inc.Cadence pleads guilty: chip design software for Chinese military university USAExport control and dual-use goods €120.1m

From 2015 to 2021, the San José provider of chip design software supplied hardware, software and semiconductor IP at least 59 times to the National University of Defense Technology (NUDT), a military university on the Entity List, disguised under the alias Central South CAD Center. Cadence pleaded guilty before the US Department of Justice to conspiracy to commit export control violations; criminal penalties of almost 118 million USD and civil penalties of more than 95 million USD imposed by the Bureau of Industry and Security (BIS) result, after crediting, in a net total of more than 140 million USD.

What organisations can take from it

Include cover names and known aliases of listed customers in screening; sales and compliance must escalate indications of military end users.

Relevance to training and awareness

Recognising aliases and cover names of listed customers

Authority / court
U.S. Department of Justice; 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); ECRA; Verschwörung zu Exportkontrollverstößen
Action
Fine
Status of proceedings
unknown
Sector
Telecoms, IT and software
Employees
10,000 or more
Culpability
intentional
Published
28 Jul 2025

Original amount 140,000,000 USD, converted at the ECB reference rate of 28 Jul 2025.

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

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21 May 2025 GoDaddy Inc.FTC: GoDaddy must set up an information security programme after hosting security gaps USASecurity measures and risk management Order

According to the Federal Trade Commission (FTC, the US consumer protection authority), the web host did not use multi-factor authentication for its hosting services, monitored security threats inadequately and did not secure connections to customer data, yet advertised “award-winning security”. The final order prohibits false statements about security and requires a comprehensive information security programme and regular reviews by independent assessors.

What organisations can take from it

Be able to prove basics such as MFA and threat monitoring before advertising security – otherwise the advertising promise itself becomes the violation.

Relevance to training and awareness

MFA, monitoring and honest security promises

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
Telecoms, IT and software
Published
21 May 2025

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

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16 Jan 2025 DoNotPay, Inc.FTC: “robot lawyer” DoNotPay pays 193,000 USD for untested AI promises USAAI systems €187,889

According to the complaint of the Federal Trade Commission (FTC, the US consumer protection authority), DoNotPay advertised its AI chatbot as “the world’s first robot lawyer” that could replace a human lawyer, without ever having tested its performance against lawyers or having it reviewed by legal professionals. The final settlement order (5–0 vote) prohibits such claims without evidence and requires 193,000 USD and notification of subscribers from 2021 to 2023 about the limitations of the legal features.

What organisations can take from it

Back performance claims for AI products with tests that prove exactly the advertised capability – “replaces the professional” is a verifiable promise.

Relevance to training and awareness

Substantiating advertising claims about AI capabilities

Authority / court
Federal Trade Commission (FTC)
Area of law
AI and digital regulation · AI systems
Legal basis
Section 5 FTC Act (irreführende Geschäftspraktiken)
Action
Order
Status of proceedings
final
Sector
Telecoms, IT and software
Published
11 Feb 2025

Original amount 193,000 USD, converted at the ECB reference rate of 16 Jan 2025.

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

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14 Jan 2025 Presto Automation Inc.SEC: “AI washing” – Presto Automation overstated the automation of its drive-thru AI USAAI systems Order

According to the Securities and Exchange Commission (SEC, the US securities regulator), the restaurant technology company, which was listed at the time, made misleading statements about its voice AI product “Presto Voice” from 2021 to 2023: it concealed that the speech recognition initially belonged to a third party and claimed that the AI eliminated the need for human order-taking, although the vast majority of orders required human intervention. The SEC issued a cease-and-desist order without a fine.

What organisations can take from it

Disclose in investor communications on AI how much human work is in the product and who owns the technology – exaggeration is a capital markets violation.

Relevance to training and awareness

Capital markets communication on AI products (“AI washing”)

Authority / court
U.S. Securities and Exchange Commission (SEC)
Area of law
AI and digital regulation · AI systems
Legal basis
Section 17(a)(2) Securities Act 1933; Section 13(a) Securities Exchange Act 1934
Action
Order
Status of proceedings
final
Sector
Telecoms, IT and software
Mitigating circumstances
No fine owing to cooperation and remedial measures.
Published
14 Jan 2025

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

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13 Jan 2025 IntelliVision Technologies Corp.FTC: IntelliVision may no longer advertise facial recognition as “free of bias” USAAI systems Order

According to the complaint of the Federal Trade Commission (FTC, the US consumer protection authority), the provider of AI facial recognition claimed without sufficient evidence that its software was among the most accurate on the market and performed without gender or skin-colour bias; contrary to its advertising, it had not been trained on millions of faces, and there was no evidence for the claim that it could not be fooled by photos or videos. The final settlement order prohibits false statements on accuracy, demographic performance and spoofing detection, as well as such statements without reliable testing.

What organisations can take from it

Treat statements on the fairness and accuracy of an AI model as advertising claims – anyone promising “bias-free” must have tested performance for each population group.

Relevance to training and awareness

Verifiable statements on the accuracy and fairness of AI models

Authority / court
Federal Trade Commission (FTC)
Area of law
AI and digital regulation · AI systems
Legal basis
Section 5 FTC Act (irreführende Geschäftspraktiken)
Action
Order
Status of proceedings
final
Sector
Telecoms, IT and software
Published
13 Jan 2025

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

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18 Dec 2024 Rytr LLCFTC bans Rytr’s AI review generator – order set aside a year later USAFake reviews overturned

According to the complaint of the Federal Trade Commission (FTC, the US consumer protection authority), the AI writing service offered a “Testimonial & Review” feature that generated detailed customer reviews with entirely invented details from brief, generic input; individual users produced hundreds to tens of thousands of reviews with it. With the final settlement order (3–2 vote), the FTC prohibited Rytr from offering any service for generating reviews. On 22 December 2025, the FTC set the order aside again with Rytr’s consent (2–0 vote): the facts alleged in the complaint did not support a violation of Section 5 of the FTC Act, and the order unduly burdened AI innovation, contrary to the Trump Administration’s AI Executive Order and AI Action Plan.

What organisations can take from it

Take responsibility for the authenticity of AI-generated reviews you publish – in the Rytr case, the FTC ultimately saw no violation in merely offering an AI writing tool.

Authority / court
Federal Trade Commission (FTC)
Area of law
Consumer protection and online retail · Fake reviews
Legal basis
Section 5 FTC Act (Mittel zur Täuschung bereitgestellt)
Action
Order
Status of proceedings
overturned
Sector
Telecoms, IT and software
Published
18 Dec 2024

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

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8 Nov 2024 Telefónica Venezolana C.A.Telefónica Venezolana: USD 85.26m for bribery in a state currency auction USABribery of public officials €79.1m

The Venezuelan subsidiary of Spain's Telefónica S.A. entered into a DPA and pays a penalty of USD 85,260,000. To be allowed to exchange bolívares for US dollars in a state currency auction in 2014, it had two suppliers pay about USD 28.9 million to an intermediary, part of which went to Venezuelan officials, and covered the cost through overpriced equipment purchases from those suppliers. It received more than USD 110 million from the auction, over 65% of the funds awarded. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

Purchases with conspicuous price mark-ups can fund bribery – pricing anomalies must be part of every compliance review.

Relevance to training and awareness

Inflated purchase prices with suppliers as a hidden channel for bribes

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
final
Sector
Telecoms, IT and software
Mitigating circumstances
Cooperation (initially diminished by late production of records) and remediation were credited: disciplinary action including dismissals, an independent compliance function with a Chief Compliance Officer, review of all non-standard pricing transactions, tighter third-party controls; 20% reduction.
Published
8 Nov 2024

Original amount 85,260,000 USD, converted at the ECB reference rate of 8 Nov 2024.

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

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1 Nov 2024 GlobalFoundries U.S. Inc.; GlobalFoundries U.S. 2 LLCBIS: USD 500,000 against GlobalFoundries for shipments to a listed company USAExport control and dual-use goods €459,348

As part of a settlement, the Bureau of Industry and Security imposed a civil penalty of USD 500,000 on GlobalFoundries U.S. Inc. and its subsidiary GlobalFoundries U.S. 2 LLC. Between February 2021 and October 2022 the company sent semiconductor wafers worth around USD 17.1 million in 74 shipments without authorisation to SJ Semiconductor, a company on the Entity List; owing to a data entry error, the service provider designated by the customer had not been screened in the screening system. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

Service providers designated by customers, such as test and assembly contractors, must also be screened against sanctions and Entity Lists.

Relevance to training and awareness

Sanctions list screening of all parties to a transaction

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
15 C.F.R. § 764.2(a) (Export Administration Regulations)
Action
Fine
Status of proceedings
final
Sector
Telecoms, IT and software
Mitigating circumstances
According to BIS, voluntary self-disclosure, cooperation and remedial measures led to a significant reduction of the penalty.
Published
1 Nov 2024

Original amount 500,000 USD, converted at the ECB reference rate of 1 Nov 2024.

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

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23 Oct 2024 Apple Inc.CFPB: Apple pays 25 million USD fine over Apple Card disputes and instalment sales USAMisleading advertising and pricing €23.2m

According to the CFPB, Apple in some cases failed to forward Apple Card users' disputes to the issuing bank Goldman Sachs and designed advertising and the checkout process so that customers wrongly assumed device purchases would automatically be split into interest-free instalments (Apple Card Monthly Installments). The order imposed a fine of 25 million USD; in September 2025 the CFPB terminated it early after the fine had been paid. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

A technology partner that designs customer interfaces for a financial product is itself liable for misleading flows and unhandled disputes.

Relevance to training and awareness

Responsibility of technology partners for customer processes in financial products

Authority / court
Consumer Financial Protection Bureau (CFPB)
Area of law
Consumer protection and online retail · Misleading advertising and pricing
Legal basis
Consumer Financial Protection Act of 2010, §§ 1031, 1036 (12 U.S.C. §§ 5531, 5536) – unlautere, irreführende und missbräuchliche Praktiken
Action
Fine
Status of proceedings
final
Sector
Telecoms, IT and software
Employees
10,000 or more
Published
23 Oct 2024

Original amount 25,000,000 USD, converted at the ECB reference rate of 23 Oct 2024.

Sources

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

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22 Oct 2024 Unisys Corp.SEC: $4 million against Unisys for downplaying cyber incidents after SolarWinds USADisclosure and reporting obligations €3.7m

In mandatory disclosures, Unisys presented cyber risks as hypothetical, although it had suffered two intrusions with data exfiltration connected with the SolarWinds compromise. On the same day, the US Securities and Exchange Commission (SEC) also imposed penalties on Avaya ($1 million), Check Point ($995,000) and Mimecast ($990,000).

What organisations can take from it

Do not describe cyber incidents that have occurred as a mere risk in investor information – disclosure processes must involve IT security.

Authority / court
U.S. Securities and Exchange Commission (SEC)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Securities Act of 1933, Securities Exchange Act of 1934 (inkl. Disclosure Controls)
Action
Fine
Status of proceedings
final
Sector
Telecoms, IT and software
Culpability
negligent
Mitigating circumstances
Cooperation in the proceedings and improvement of cybersecurity controls.
Published
22 Oct 2024

Original amount 4,000,000 USD, converted at the ECB reference rate of 22 Oct 2024.

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

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9 Sep 2024 a US software providerSEC: US software provider pays 692,250 US dollars over waivers of whistleblower awards USARetaliation against whistleblowersanonymised €626,868

The provider of property management software had employees waive potential awards for reports to authorities in two employment agreements and one settlement agreement; 68 consulting agreements (January 2020 to October 2023) prohibited voluntary disclosures to authorities. As part of a sweep against seven listed companies, the provider paid 692,250 US dollars to the U.S. Securities and Exchange Commission (SEC); the contract templates were amended.

What organisations can take from it

Separation and employment agreements must restrict neither reports to authorities nor the entitlement to whistleblower awards.

Relevance to training and awareness

Whistleblower protection in contract templates (HR/Legal)

Authority / court
U.S. Securities and Exchange Commission
Area of law
Whistleblower protection · Retaliation against whistleblowers
Legal basis
Securities Exchange Act of 1934, Rule 21F-17(a)
Action
Fine
Status of proceedings
final
Sector
Telecoms, IT and software
Employees
1,000 to 9,999
Mitigating circumstances
Amendment of the templates after contact by the SEC, information provided to those affected, and cooperation
Published
9 Sep 2024

Original amount 692,250 USD, converted at the ECB reference rate of 9 Sep 2024.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 9 Sep 2026 · Direct link

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26 Jun 2024 a British software maker and two subsidiariesSoftware maker: 16.5 million USD and ban on selling browsing data USACookies and trackinganonymised €15.4m

The FTC issued its final order against a British software maker, its Czech subsidiary and its former data subsidiary. According to the authority, the software maker collected detailed browsing data through browser extensions and antivirus software, stored it indefinitely and sold it via the data subsidiary to more than 100 third parties without adequate notice and consent, even though the products were marketed as protecting against online tracking. The software maker must pay 16,500,000 USD for consumer redress, may no longer sell or license browsing data for advertising purposes, must delete the data transferred to the data subsidiary together with any products and algorithms derived from it, and must set up a privacy programme.

What organisations can take from it

A company that advertises protection against tracking must not monetise the same usage data itself – marketing claims and data use must match.

Relevance to training and awareness

Privacy promises versus actual data use; sale of usage data

Authority / court
Federal Trade Commission (FTC)
Area of law
Data protection · Cookies and tracking
Legal basis
Section 5(a) FTC Act, 15 U.S.C. § 45(a) (unlautere und irreführende Praktiken)
Action
Disgorgement of profits
Status of proceedings
final
Sector
Telecoms, IT and software
Published
27 Jun 2024

Original amount 16,500,000 USD, converted at the ECB reference rate of 26 Jun 2024.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 26 Jun 2026 · Direct link

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20 May 2024 a US data services providerFTC: US data services provider must delete legacy data and strengthen security after hacker attack USASecurity measures and risk managementanonymised Order

According to the complaint of the Federal Trade Commission (FTC, the US consumer protection authority), an attacker exploited weaknesses in the network of the data services provider for companies and non-profit organisations in early 2020 and stole large amounts of unencrypted data, including Social Security and bank account numbers of millions of people; the attack went undetected for three months, the provider informed its customers only after almost two months and misrepresented the extent. The final order requires a comprehensive security programme, a data retention schedule, deletion of data no longer needed and notification of future reportable incidents to the FTC.

What organisations can take from it

Set retention periods and deletion routines as security measures – data that is no longer needed is pure risk in an attack.

Relevance to training and awareness

Data minimisation, encryption and honest incident communication

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
Telecoms, IT and software
Published
20 May 2024

Checked against the official source on 28 Sep 2026 · Version 3 · Company name anonymised since 20 May 2026 · Direct link

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12 Jun 2023 a Chinese manufacturer of printers and printer suppliesUFLPA list: Chinese printer manufacturer and eight subsidiaries added USAForced and child labouranonymised Order

The U.S. Forced Labor Enforcement Task Force (FLETF) added the manufacturer and eight subsidiaries to the Uyghur Forced Labor Prevention Act (UFLPA) Entity List because they work with the Xinjiang government on the recruitment, transport or reception of forced labourers. The company's goods are therefore presumed to have been produced with forced labour on import into the US unless the importer rebuts this.

What organisations can take from it

IT procurement should screen manufacturers of printers, toner and chips against forced labour lists – including subsidiaries.

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)(ii)
Action
Order
Status of proceedings
unknown
Sector
Telecoms, IT and software
Published
12 Jun 2023
Sources

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 12 Jun 2025 · Direct link

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19 Apr 2023 a US hard disk drive manufacturer and its entity in SingaporeBIS: USD 300 million against US hard drive maker for shipments to Chinese group USAExport control and dual-use goodsanonymised €274.4m

The Bureau of Industry and Security imposed a civil penalty of USD 300 million on a US hard disk drive manufacturer and its international headquarters in Singapore, payable in 20 quarterly instalments of USD 15 million. Between August 2020 and September 2021, the manufacturer supplied around 7.4 million foreign-produced hard disk drives worth about USD 1.1 billion on 429 occasions without authorisation to entities of a Chinese telecommunications group on the Entity List, although these were subject to the foreign direct product rule. The order also provides for three audits of the export compliance programme and a denial order suspended for five years.

What organisations can take from it

The foreign direct product rule also covers products manufactured abroad – supply chains must be checked for US technology used in production.

Relevance to training and awareness

Foreign direct product rule and supplies to companies on the Entity List

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
15 C.F.R. § 764.2(a) (Export Administration Regulations); Export Control Reform Act of 2018 (50 U.S.C. §§ 4801–4852)
Action
Fine
Status of proceedings
final
Sector
Telecoms, IT and software
Published
19 Apr 2023

Original amount 300,000,000 USD, converted at the ECB reference rate of 19 Apr 2023.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 19 Apr 2025 · Direct link

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