Compliance Radar

Who was sanctioned, and for what?

Fines, court rulings and incidents from Europe and North America: 756 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.

1case from 1 jurisdiction
€338.4mTotal of monetary amounts
€338.4mLargest single case: RTX Corporation (Raytheon Company)
€338.4mMedian per case with an amount

Click a bar to drill down one level.

When?

per quarter, by date of decision
Trend
PeriodCasesTotal
Q3 20230—
Q4 20230—
Q1 20240—
Q2 20240—
Q3 20240—
Q4 20241€338.4m
Q1 20250—
Q2 20250—
Q3 20250—
Q4 20250—
Q1 20260—
Q2 20260—
Q3 20260—

1 case

16 Oct 2024 RTX Corporation (Raytheon Company)RTX (Raytheon) pays around 391 million USD for bribing a Qatari military official USABribery of public officials €338.4m

From 2011 to 2017, Raytheon paid almost 2 million USD via sham subcontracts to Qatari military and other public officials and more than 30 million USD to an agent from the ruling family. SEC order: disgorgement of 37,400,090 USD, interest of 11,786,208 USD and a penalty of 75 million USD (of which 22.5 million USD was credited against the DOJ payment); under the DPA with the DOJ, 267,096,068 USD (230.4 million penalty, 36,696,068 forfeiture) is attributable to the FCPA part, combined with an Arms Export Control Act violation and a three-year monitorship. Total without double counting: 368,782,366 USD.

What organisations can take from it

Subcontracts without verifiable services are a classic vehicle for bribes – defence exporters must also disclose payment flows to export control authorities.

Relevance to training and awareness

Sham subcontracts and agents in defence transactions

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, Sections 30A, 13(b)(2)(A)/(B) Exchange Act); Arms Export Control Act; DPA
Action
Fine
Status of proceedings
final
Sector
Defence and security
Employees
10,000 or more
Culpability
intentional
Published
16 Oct 2024

Original amount 368,782,366 USD, converted at the ECB reference rate of 16 Oct 2024.

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

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