Who was sanctioned, and for what?

On board the MSC Samira III, senior engineering officers had oily bilge water pumped overboard via the sewage tank, bypassing the oily water separator, in 2024/2025, manipulated the oil content monitoring and falsified the oil record book, which was presented to the Coast Guard in Philadelphia. The operator and the owner each pleaded guilty to two counts under the Act to Prevent Pollution from Ships (APPS) and are paying a combined 1.75 million USD; in addition, there are four years of probation.

Authority / court

U.S. District Court for the Eastern District of Pennsylvania (Anklage: DOJ Environment and Natural Resources Division)

Area of law

Environment and sustainability · Waste and hazardous substances

Legal basis

Act to Prevent Pollution from Ships (APPS), 33 U.S.C. § 1908

Action

Fine

Status of proceedings

unknown

Sector

Transport, logistics and shipping

Employees

10,000 or more

Culpability

intentional

Liability of senior managers

Second Engineer Mikhail Tsurikov also pleaded guilty; sentencing scheduled for 10 September 2026.

Published

28 Aug 2026

Original amount 1,750,000 USD, converted at the ECB reference rate of 28 Aug 2026.

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

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In May 2022, bypassing internal compliance procedures, the Houston freight forwarder engaged a blocked Venezuelan state-owned airline for a shipment from Mexico to Argentina; the aircraft used, which was also blocked, was operated by Iran's Mahan Air. The US Treasury's Office of Foreign Assets Control (OFAC) classified the case as egregious and not voluntarily self-disclosed, partly because two vice presidents bypassed the screening under time pressure.

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

Venezuela-, Iran-, Proliferations- und Terrorismus-Sanktionsprogramme (OFAC); IEEPA

Action

Fine

Status of proceedings

final

Sector

Transport, logistics and shipping

Culpability

negligent

Repeat case

no

Mitigating circumstances

No prior violations in five years, immediate remediation, substantial cooperation

Liability of senior managers

According to OFAC, the violation was driven primarily by two vice presidents who bypassed internal screening processes.

Published

3 Sep 2025

Original amount 1,610,775 USD, converted at the ECB reference rate of 3 Sep 2025.

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

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On board the tanker M/T Swift Winchester, a hose connected the incinerator's waste oil tank to the sewage tank from February to August 2022, so that oily waste bypassed the pollution prevention equipment and went into the sea; in August 2022, an oily water separator filter was also hosed down with degreaser on deck and the oily mixture ran overboard. The vessel called at Baton Rouge and Port Arthur with a knowingly falsified oil record book. The ship management company pleaded guilty and is paying a fine of 2 million USD.

Authority / court

U.S. District Court for the Eastern District of Texas (Anklage: DOJ Environment and Natural Resources Division)

Area of law

Environment and sustainability · Waste and hazardous substances

Legal basis

Act to Prevent Pollution from Ships (APPS)

Action

Fine

Status of proceedings

unknown

Sector

Transport, logistics and shipping

Culpability

intentional

Published

27 Aug 2025

Original amount 2,000,000 USD, converted at the ECB reference rate of 27 Aug 2025.

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

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After the acquisition of a Colombian logistics company in December 2021, the latter organised 36 freight shipments to Cuba worth around 3.06 million USD up to July 2023. Neither the US parent nor the subsidiary had a sanctions compliance programme for foreign companies; the US Treasury's Office of Foreign Assets Control (OFAC) assessed the case as non-egregious and voluntarily self-disclosed.

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

Cuban Assets Control Regulations (31 C.F.R. part 515)

Action

Fine

Status of proceedings

final

Sector

Transport, logistics and shipping

Culpability

negligent

Repeat case

no

Mitigating circumstances

Voluntary self-disclosure, no prior violations, remedial measures after discovery

Published

2 Jul 2025

Original amount 608,825 USD, converted at the ECB reference rate of 2 Jul 2025.

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

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In the view of the U.S. Environmental Protection Agency (EPA), the freight railway operated locomotives without a certificate of conformity, did not comply with the conditions of a testing exemption for several locomotives and operated locomotives in breach of the applicable emission standards. Under the settlement (Consent Agreement and Final Order), the company is paying a civil penalty of 299,000 USD.

Authority / court

U.S. Environmental Protection Agency (EPA), Region 3

Area of law

Environment and sustainability · Emissions and permits

Legal basis

Clean Air Act §§ 203(a), 213(d) (42 U.S.C. §§ 7522(a), 7547(d)); 40 C.F.R. § 1068.101

Action

Fine

Status of proceedings

final

Sector

Transport, logistics and shipping

Employees

10,000 or more

Original amount 299,000 USD, converted at the ECB reference rate of 14 May 2025.

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

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Through an agent and a joint venture partner, AAR paid sham commissions to public officials in order to secure the sale of two Airbus A330s to Nepal Airlines and maintenance services for South African Airways Technical. SEC: 23,451,100 USD in disgorgement and 5,785,524 USD in interest; DOJ criminal penalty of 26,363,029 USD under a Non-Prosecution Agreement.

Authority / court

U.S. Securities and Exchange Commission (SEC); U.S. Department of Justice

Area of law

Bribery and corruption · Bribery of public officials

Legal basis

FCPA (Anti-Bestechung, Buchführung, interne Kontrollen); Non-Prosecution Agreement

Action

Fine

Status of proceedings

final

Sector

Transport, logistics and shipping

Employees

1,000 to 9,999

Culpability

intentional

Mitigating circumstances

Disclosure following press reports, cooperation (forensics, translations, witnesses) and remedial measures.

Liability of senior managers

A former senior employee of an AAR subsidiary, Deepak Sharma (named in the SEC order), was involved.

Published

19 Dec 2024

Original amount 55,599,653 USD, converted at the ECB reference rate of 19 Dec 2024.

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

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From November 2018 to February 2022, five foreign subsidiaries of the logistics group acquired through takeovers brokered or transported a total of 82 shipments involving Iranian or Cuban goods or an Iranian airline. The main cause was that their booking systems had not yet been integrated into the group's screening processes; the US Treasury's Office of Foreign Assets Control (OFAC) considered the case non-egregious and voluntarily self-disclosed.

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; Cuban Assets Control Regulations

Action

Fine

Status of proceedings

final

Sector

Transport, logistics and shipping

Employees

10,000 or more

Culpability

negligent

Repeat case

no

Mitigating circumstances

Voluntary self-disclosure, no prior violations, swift remediation

Published

13 Dec 2024

Original amount 257,690 USD, converted at the ECB reference rate of 13 Dec 2024.

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

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UPS based the valuation of UPS Freight on a consultant's appraisal of around 2 billion USD, although its own analyses had arrived at only about 650 million USD, and did not record a required goodwill impairment. UPS is paying 45 million USD and must introduce training for certain executives, board members and employees and engage an independent compliance consultant.

Authority / court

U.S. Securities and Exchange Commission (SEC)

Area of law

Capital markets and financial supervision · Disclosure and reporting obligations

Legal basis

Section 17(a)(2),(3) Securities Act; Reporting-, Buchführungs-, interne Kontroll- und Disclosure-Controls-Vorschriften des Exchange Act

Action

Fine

Status of proceedings

final

Sector

Transport, logistics and shipping

Original amount 45,000,000 USD, converted at the ECB reference rate of 22 Nov 2024.

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

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