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.

EUGermany Clear all filters
51cases from 1 jurisdiction
€230.8mTotal of monetary amounts (34 cases with an amount)
€416,252Median per case with an amount

Click a bar to drill down one level.

Where?

by authority
  1. Bundeskartellamt €96.7m 42 % · 7 cases
  2. Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin) €61.7m 27 % · 13 cases
  3. Bundesbeauftragte für den Datenschutz und die Informationsfreiheit (BfDI) €45m 19 % · 1 case
  4. Landgericht Würzburg (Wirtschaftsstrafkammer); Ermittlungen Zollfahndungsamt Essen und Staatsanwaltschaft Würzburg €20m 9 % · 1 case
  5. Landgericht Marburg; Ermittlungen Staatsanwaltschaft Frankfurt am Main und Zollfahndungsamt Essen €5m 2 % · 1 case
  6. Oberlandesgericht Stuttgart, 7. Strafsenat (Az. 7 St 3 BJs 119/23) €880,000 0 % · 1 case
  7. Hauptzollamt Karlsruhe (Finanzkontrolle Schwarzarbeit) €513,731 0 % · 2 cases
  8. Bezirksregierung Arnsberg (Geldwäscheaufsicht Nichtfinanzsektor) €392,370 0 % · 2 cases
  9. Hauptzollamt Singen (Finanzkontrolle Schwarzarbeit) €232,500 0 % · 1 case
  10. Hamburgischer Beauftragter für Datenschutz und Informationsfreiheit (HmbBfDI) €195,000 0 % · 1 case
  11. 20 more€159,116

What for?

by area of law

All areas of law

  1. Competition law €96.7m 42 % · 7 cases
  2. Money laundering and terrorist financing €58.6m 25 % · 9 cases
  3. Data protection €45.2m 20 % · 5 cases
  4. Sanctions and export control €26m 11 % · 7 cases
  5. Capital markets and financial supervision €3.46m 1 % · 8 cases
  6. Health and safety and employment law €797,547 0 % · 8 cases
  7. Consumer protection and online retail — 0 % · 3 cases
  8. Bribery and corruption — 0 % · 2 cases
  9. Environment and sustainability — 0 % · 2 cases

Who?

by sector

All sectors

  1. Construction and real estate €78.6m 34 % · 9 cases
  2. Financial services and insurance €58.4m 25 % · 6 cases
  3. Telecoms, IT and software €47m 20 % · 3 cases
  4. Automotive €37.1m 16 % · 6 cases
  5. Retail and e-commerce €7.46m 3 % · 6 cases
  6. Manufacturing and mechanical engineering €1.35m 1 % · 6 cases
  7. Food and agriculture €500,000 0 % · 2 cases
  8. Transport, logistics and shipping €248,731 0 % · 5 cases
  9. Steel and metals €100,000 0 % · 2 cases
  10. Other — 0 % · 2 cases
  11. 4 more€0

When?

per quarter, by date of decision
Trend
PeriodCasesTotal
Q3 20230—
Q4 20232€5.08m
Q1 20243€700,000
Q2 20243€9.21m
Q3 20241€880,000
Q4 20243€2.79m
Q1 20252€800
Q2 20256€63.3m
Q3 20256€9m
Q4 20257€45.4m
Q1 20266€20.5m
Q2 20263€620,000
Q3 20269€73.3m

51 cases

6 Aug 2026 AS Asphaltstraßensanierung GmbH, BITUNOVA GmbH, Kutter Spezialstraßenbau GmbH & Co. KG, Possehl Construction GmbH (inkl. VSI), Liesen…alles für den Bau GmbH, OAT GmbH/Otto Alte-Teigeler GmbHBundeskartellamt: 60.3 million EUR against DSK road repair cartel GermanyCartels and collusion €60.3m

From around 2010 to September 2019, six suppliers of thin cold-laid asphalt surface layers (Dünne Asphaltdeckschichten in Kaltbauweise, DSK) allocated customers – primarily public contracting authorities – and contracts among themselves nationwide and coordinated prices. Germany's Federal Cartel Office (Bundeskartellamt) imposed fines of around 60.3 million EUR; all proceedings ended in settlements.

What organisations can take from it

Anyone who "shares out" public contracts regionally risks fines running into millions – calculations and bids must always be prepared independently.

Relevance to training and awareness

Customer allocation and bid rigging in public contracts

Authority / court
Bundeskartellamt
Area of law
Competition law · Cartels and collusion
Legal basis
§ 1 GWB, Art. 101 AEUV
Action
Fine
Status of proceedings
final
Sector
Construction and real estate
Mitigating circumstances
Leniency bonus for Possehl/VSI, Bitunova, Kutter and AS; settlement
Published
6 Aug 2026

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

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23 Sep 2026 BGH upholds conviction of a procurement head of unit at the OLG Jena for accepting benefits GermanyBribery of public officials Custodial sentence

A head of unit at the Higher Regional Court of Jena (OLG Jena) responsible for budget, procurement and personnel of the Thuringian judiciary obtained fourteen loans (375 to 10,000 EUR) from two co-defendants between 2013 and 2019, coupled with the tacit expectation that he would take them into account when awarding contracts; he also concluded service contracts in breach of public procurement law (damage exceeding 450,000 EUR). The Regional Court of Gera (LG Gera) imposed an aggregate suspended prison sentence of two years and confiscation. Germany's Federal Court of Justice (Bundesgerichtshof, BGH) upheld the conviction for accepting benefits (Vorteilsannahme, not Bestechlichkeit, i.e. taking bribes) in 13 cases, discontinued one time-barred case and set aside the aggregate sentence and the amount of the daily fine rate; the defendant's appeal on points of law will be decided separately.

What organisations can take from it

Private loans from suppliers to procurement officers are a criminal offence even without a specific quid pro quo – contracting authorities need clear rules and staff rotation.

Relevance to training and awareness

Loans and benefits from contractors to procurement officers

Authority / court
Bundesgerichtshof (2. Strafsenat); Vorinstanz Landgericht Gera
Area of law
Bribery and corruption · Bribery of public officials
Legal basis
§ 331 StGB (Vorteilsannahme), § 266 StGB (Untreue); BGH 2 StR 554/25
Action
Custodial sentence
Status of proceedings
under appeal
Sector
Public sector
Culpability
intentional
Liability of senior managers
The former head of unit (a management function in the judicial administration) was convicted; two lenders were co-defendants.
Published
23 Sep 2026

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

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12 Aug 2026 40 lorry drivers hired out under sham service contract: 35,000 EUR in fines for haulage firms GermanyMinimum wage and undeclared work €35,000

A German haulage operator deployed 40 foreign drivers from two affiliated Lithuanian transport companies under his sole direction; the hiring-out of workers was disguised as a contract for work and services (Werkvertrag), and there was no licence from the Federal Employment Agency (Bundesagentur für Arbeit). Final fines: 20,000 EUR against the Lithuanian managing director and 15,000 EUR against the German hirer (date = publication).

What organisations can take from it

What counts is actual practice: companies that deploy and direct third-party drivers like their own staff are engaged in temporary agency work – regardless of what the contract says.

Authority / court
Hauptzollamt Lörrach (Finanzkontrolle Schwarzarbeit)
Area of law
Health and safety and employment law · Minimum wage and undeclared work
Legal basis
Arbeitnehmerüberlassungsgesetz (Überlassung ohne Erlaubnis)
Action
Fine
Status of proceedings
final
Sector
Transport, logistics and shipping
Liability of senior managers
Fines imposed personally on the managing director of the lending company and on the hirer.
Published
12 Aug 2026

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

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21 Jul 2026 Maxxis International GmbH, Best4Tires Berlin GmbH, Reifen Müller GmbH & Co. KGBundeskartellamt: 11.9 million EUR over resale price maintenance in tyre distribution (Maxxis/CST) GermanyCartels and collusion €11.9m

Maxxis guaranteed wholesalers fixed margins per tyre sold of the Maxxis and CST brands, monitored prices in particular on the Tyre24 platform and intervened when prices were too low. Germany's Federal Cartel Office (Bundeskartellamt) imposed fines totalling 11.9 million EUR on three companies and one responsible individual.

What organisations can take from it

Margin guarantees and price controls vis-à-vis dealers constitute prohibited resale price maintenance – sales teams need clear rules for price discussions.

Relevance to training and awareness

Influencing resale prices and price monitoring on platforms

Authority / court
Bundeskartellamt
Area of law
Competition law · Cartels and collusion
Legal basis
§ 1 GWB (vertikale Preisbindung)
Action
Fine
Status of proceedings
unknown
Sector
Automotive
Mitigating circumstances
Settlement with Maxxis and Reifen Müller
Liability of senior managers
Fine imposed on one responsible natural person (not named)
Published
21 Jul 2026

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

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16 Jul 2026 TeamViewer SETeamViewer: cyberattack not disclosed as inside information without delay GermanyDisclosure and reporting obligations €240,000

Germany's Federal Financial Supervisory Authority (Bundesanstalt für Finanzdienstleistungsaufsicht, BaFin) imposed a fine of 240,000 EUR on the software company because it had not disclosed the information about a cyberattack it had suffered as inside information without delay. The fine notice is final.

What organisations can take from it

Put serious IT security incidents immediately before the ad hoc disclosure committee as well – the incident response process must take capital market disclosure into account.

Relevance to training and awareness

Recognising security incidents as potential inside information and reporting them to the ad hoc disclosure committee

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Art. 17 Abs. 1 UAbs. 1 MAR (EU) Nr. 596/2014
Action
Fine
Status of proceedings
final
Sector
Telecoms, IT and software
Published
20 Jul 2026

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

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16 Jul 2026 BGH: online cancellation page must not offer a "pause contract" alternative GermanyInformation duties in online retail Order

On the confirmation page of its online cancellation process, a gym operator displayed a highlighted notice with the button "Pause contract via self-service"; in addition, the confirmation button was labelled "Find contract", which the defendant had already acknowledged. In an action brought by the Federation of German Consumer Organisations (Verbraucherzentrale Bundesverband), the BGH ruled that the confirmation page may only contain the information required for the cancellation and the confirmation button, set aside the judgment of the Higher Regional Court of Düsseldorf (OLG Düsseldorf) dismissing the action to that extent and ordered the operator to cease and desist.

What organisations can take from it

Keep retention or pause offers off the confirmation page of the online cancellation process.

Relevance to training and awareness

Design of the cancellation process (cancellation button, retention offers)

Authority / court
Bundesgerichtshof (I. Zivilsenat), Az. I ZR 200/25
Area of law
Consumer protection and online retail · Information duties in online retail
Legal basis
§ 312k Abs. 1 Satz 1, Abs. 2 BGB (Kündigungsbutton)
Action
Order
Status of proceedings
final
Sector
Other
Published
16 Jul 2026

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

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15 Jul 2026 CalPlus GmbH, Elektronik-Kontor Messtechnik GmbH, TVW Meßtechnik GmbHBundeskartellamt: 453,000 EUR against distributors of test and measuring equipment GermanyCartels and collusion €453,000

From 2016 to 2022, three distributors of test and measuring equipment coordinated discounts as essential price components and informed each other of customer contacts, usually with a request for "restraint". This was evidenced by more than 400 emails; the proceedings ended in settlements.

What organisations can take from it

Small distributors are liable too: merely asking a competitor to "hold back" with a customer is a prohibited customer allocation agreement.

Relevance to training and awareness

Email contacts with competitors about customers and discounts

Authority / court
Bundeskartellamt
Area of law
Competition law · Cartels and collusion
Legal basis
§ 1 GWB
Action
Fine
Status of proceedings
final
Sector
Manufacturing and mechanical engineering
Mitigating circumstances
Settlement; cooperation by Elektronik-Kontor Messtechnik taken into account
Published
15 Jul 2026

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

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10 Jul 2026 Volksbank Düsseldorf Neuss eGBaFin: 210,000 EUR against Volksbank Düsseldorf Neuss over monitoring and reporting gaps GermanyCustomer due diligence €210,000

Germany's Federal Financial Supervisory Authority (BaFin) imposed fines totalling 210,000 EUR on the cooperative bank: business relationships were not monitored on an ongoing basis or with enhanced scrutiny, additional information was not obtained and suspicious activity reports were not filed or were filed late. The function of the money laundering reporting officer had been outsourced to an external service provider with several clients.

What organisations can take from it

Institutions that outsource the anti-money laundering function remain responsible themselves for ongoing monitoring and timely suspicious activity reports.

Relevance to training and awareness

Ongoing monitoring of business relationships and suspicious activity reporting

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
§ 56 Abs. 1 S. 1 Nr. 20, 36, 38 und 69 GwG; Bekanntmachung nach § 57 GwG
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
17 Sep 2026

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

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10 Jul 2026 Brown Capital Management LLCBrown Capital Management: voting rights notifications not submitted on time GermanyDisclosure and reporting obligations €187,500

The Baltimore-based US asset manager had not submitted voting rights notifications to the issuer and BaFin in time; the deadline is four trading days after reaching a notifiable threshold. BaFin imposed a fine of 187,500 EUR; the notice is final.

What organisations can take from it

Anyone investing in German issuers needs automated threshold monitoring with clear responsibility for the four-day deadline.

Relevance to training and awareness

Threshold monitoring and notification deadlines for shareholdings

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
§ 33 Abs. 1 Satz 1 WpHG
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
22 Jul 2026

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

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23 Jun 2026 VARTA AGVARTA: late ad hoc announcement and missing half-yearly financial report GermanyDisclosure and reporting obligations €620,000

BaFin imposed fines on the battery manufacturer because it had not disclosed inside information without delay and had not published the half-yearly financial report for the 2024 financial year.

What organisations can take from it

Ad hoc assessments and periodic disclosure require fixed responsibilities and deadline controls so that neither inside information nor mandatory reports are left pending.

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Art. 17 Abs. 1 UAbs. 1 MAR; § 115 Abs. 1 Satz 1 WpHG
Action
Fine
Status of proceedings
final
Sector
Manufacturing and mechanical engineering
Published
1 Jul 2026

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

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9 Jun 2026 Deutsche Wohnen SELG Berlin I confirms GDPR infringement by Deutsche Wohnen through tenant archive without deletion function GermanyData breaches and data security Fine

In 2019, the Berlin Commissioner for Data Protection and Freedom of Information (BlnBDI) had imposed 14.5 million EUR on the housing group because tenant data such as salary statements, bank statements and social security data were held in an archive system with no means of deletion. Following the 2023 CJEU judgment on direct corporate liability, the Berlin Regional Court (Landgericht Berlin I) confirmed on 9 June 2026 infringements of data minimisation and storage limitation; the press release does not state the amount of the fine set by the court.

What organisations can take from it

Ensure that archive and filing systems can technically implement deletion periods from the outset – ‘privacy by design’ is subject to fines.

Authority / court
Landgericht Berlin I (Bußgeldbehörde: Berliner Beauftragte für Datenschutz und Informationsfreiheit)
Area of law
Data protection · Data breaches and data security
Legal basis
Art. 5, Art. 25 Abs. 1 DSGVO
Action
Fine
Status of proceedings
unknown
Sector
Construction and real estate
Liability of senior managers
According to the CJEU (C-807/21), a breach of duty by a person in a management position need not be proven for the corporate fine.
Published
10 Jun 2026

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

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4 May 2026 Berliner Verkehrsbetriebe (BVG) AöRBlnBDI reprimands BVG: deletion at service provider not checked, data breach reported too late GermanyData processors Reprimand or warning

A processor of Berlin's public transport operator BVG, which had sent customer letters in early 2025, was hacked; around 180,000 customer records were affected, although they should long since have been deleted after the end of the contract. BVG had never checked the deletion, had not agreed any procedure for data breaches in the data processing agreement and reported the incident only after the 72-hour deadline had expired; the Berlin Commissioner for Data Protection and Freedom of Information (BlnBDI) issued a reprimand.

What organisations can take from it

Have service providers prove deletion after the end of the contract, and have an internal procedure that immediately turns indications of a breach into a 72-hour notification.

Relevance to training and awareness

Reporting process for data breaches and management of service providers

Authority / court
Berliner Beauftragte für Datenschutz und Informationsfreiheit (BlnBDI)
Area of law
Data protection · Data processors
Legal basis
Art. 5 Abs. 2 i. V. m. Abs. 1 lit. c, e, f, Art. 28 Abs. 3 S. 2 lit. f, Art. 32 Abs. 1, Art. 33 DSGVO
Action
Reprimand or warning
Status of proceedings
unknown
Sector
Transport, logistics and shipping
Mitigating circumstances
BVG has announced measures against similar incidents.
Published
4 May 2026
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31 Mar 2026 Anti-dumping duty evaded: suspended sentence and fine for import of hairdressing aluminium foil GermanyCustoms €100,000

A German import company declared aluminium foil for hairdressers made in China as goods originating in Myanmar in order to evade anti-dumping duties; a company set up specifically for this purpose in Myanmar carried out only minimal processing, which did not change the origin. Around 610,000 EUR was evaded, plus around 140,000 EUR from seven direct sales to unsuspecting German customers. Following charges brought by the European Public Prosecutor's Office (EPPO) in Cologne, the Krefeld District Court sentenced the Chinese national responsible to one year and eight months suspended and a fine of 100,000 EUR; more than 321,000 EUR was confiscated, and the proceedings against a second accused were discontinued subject to a monetary condition.

What organisations can take from it

Origin declarations for metal goods subject to anti-dumping duty must be robust – minimal processing in a third country does not change the origin.

Relevance to training and awareness

Origin of goods and proof of origin for goods subject to anti-dumping duties

Authority / court
Gericht in Krefeld (Krefeld District Court); Anklage: Europäische Staatsanwaltschaft (EPPO) Köln; Ermittlungen Zollfahndungsamt Essen
Area of law
Sanctions and export control · Customs
Legal basis
Hinterziehung von EU-Antidumpingzöllen (Einfuhrabgaben) auf Aluminiumfolie aus China; Ursprungsregeln des EU-Zollrechts
Action
Custodial sentence
Status of proceedings
unknown
Sector
Steel and metals
Culpability
intentional
Published
31 Mar 2026

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

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4 Mar 2026 Schaeffler AGSchaeffler: deviation of quarterly figures from market expectations disclosed too late GermanyDisclosure and reporting obligations €180,000

The automotive supplier's business figures for the first quarter of 2024 deviated significantly from market expectations; this inside information was not disclosed without delay by means of an ad hoc announcement. BaFin imposed a fine.

What organisations can take from it

Make a comparison of internal figures with the analyst consensus a fixed part of the quarterly process, so that significant deviations are immediately assessed for ad hoc disclosure obligations.

Relevance to training and awareness

Recognising inside information in deviations from market expectations (controlling/IR)

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Art. 17 Abs. 1 UAbs. 1 MAR
Action
Fine
Status of proceedings
final
Sector
Automotive
Published
26 Mar 2026

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2 Mar 2026 Autohandel aus dem Landkreis Miltenberg (Inhaber Andreas M.)Six years' imprisonment for car dealer: 111 luxury vehicles to Russia despite embargo GermanyBreaches of sanctions and embargoes €20m

A car dealer from the Bavarian Lower Main region specialising in armoured and luxury vehicles brought 111 vehicles worth almost 20 million EUR to Russia, and around 400 further vehicles were planned. The white-collar crime chamber of the Würzburg Regional Court (Landgericht Würzburg) sentenced the owner to six years' imprisonment and the former authorised signatory (Prokuristin) to two years suspended, and ordered the confiscation of around 20 million EUR; the judgment is not final.

What organisations can take from it

Bans on luxury goods to Russia are enforced with long prison sentences and confiscation of assets; authorised signatories are also personally liable.

Authority / court
Landgericht Würzburg (Wirtschaftsstrafkammer); Ermittlungen Zollfahndungsamt Essen und Staatsanwaltschaft Würzburg
Area of law
Sanctions and export control · Breaches of sanctions and embargoes
Legal basis
Außenwirtschaftsgesetz i. V. m. Russland-Embargoverordnung (EU) Nr. 833/2014 (gewerbsmäßig)
Action
Custodial sentence
Status of proceedings
unknown
Sector
Automotive
Culpability
intentional
Liability of senior managers
Owner (Andreas M.) six years' imprisonment; former authorised signatory (Inna W.) two years suspended.
Published
2 Mar 2026

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

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23 Feb 2026 15 construction workers not registered: criminal fine and administrative fine for managing director GermanyMinimum wage and undeclared work €16,316

A Romanian construction firm, acting as a subcontractor for a Düsseldorf client, deployed 15 workers on a construction site in the district of Emmendingen without registering them for social insurance; the loss amounted to around 85,000 EUR. The managing director received a final penalty order (Strafbefehl) of 15,000 EUR and a fine of 1,316 EUR (date = publication).

What organisations can take from it

Companies that deploy foreign workers must be able to prove social insurance coverage in the country of origin (A1 certificate) – otherwise German contribution law applies.

Authority / court
Amtsgericht Kenzingen / Hauptzollamt Lörrach (Finanzkontrolle Schwarzarbeit)
Area of law
Health and safety and employment law · Minimum wage and undeclared work
Legal basis
§ 266a StGB (Vorenthalten und Veruntreuen von Arbeitsentgelt); SGB IV (Meldepflichten)
Action
Fine
Status of proceedings
final
Sector
Construction and real estate
Culpability
intentional
Liability of senior managers
Managing director personally convicted by penalty order.
Published
23 Feb 2026

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22 Jan 2026 Logistics business: fines for minimum wage, reporting and foreign employment violations GermanyMinimum wage and undeclared work €13,731

Between June and December 2023, a logistics and transport business withheld a total of around 2,000 EUR in minimum wages from several employees, breached reporting and immediate notification obligations, and in July/August 2023 employed a foreign national without a residence permit. The fines: 5,231 EUR (minimum wage), 750 EUR each (reporting obligations) and 7,000 EUR (unauthorised employment of foreign nationals), totalling 13,731 EUR (date = publication).

What organisations can take from it

Even small wage arrears are penalised individually alongside reporting and residence violations – HR processes for new hires need a fixed checklist.

Relevance to training and awareness

Immediate notification and checking of work permits when hiring

Authority / court
Hauptzollamt Karlsruhe (Finanzkontrolle Schwarzarbeit)
Area of law
Health and safety and employment law · Minimum wage and undeclared work
Legal basis
§ 21 Abs. 1 Nr. 11 MiLoG; § 111 Abs. 1 Nr. 2 SGB IV; § 404 Abs. 2 Nr. 3 SGB III
Action
Fine
Status of proceedings
unknown
Sector
Transport, logistics and shipping
Published
22 Jan 2026

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

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9 Jan 2026 Bulgarian construction subcontractor: 232,500 EUR for paying below the minimum wage GermanyMinimum wage and undeclared work €232,500

A Bulgarian construction company that worked as a subcontractor for a German firm on a major construction site in the district of Tuttlingen between January and May 2023 paid below the minimum wage, recorded only the duration of working time rather than its start and end, and did not register the posting. The decisions issued in September 2025, final since the end of 2025, amount to 232,500 EUR – of which 215,000 EUR is disgorgement of the economic benefit and 17,500 EUR is imposed on the managing director (date = publication; exact date of the decision not specified).

What organisations can take from it

General contractors should actively check the minimum wage, working time records and posting notifications of their foreign subcontractors – the economic benefit is disgorged in full.

Authority / court
Hauptzollamt Singen (Finanzkontrolle Schwarzarbeit)
Area of law
Health and safety and employment law · Minimum wage and undeclared work
Legal basis
Mindestlohngesetz; Arbeitnehmer-Entsendegesetz (Aufzeichnungs- und Meldepflichten)
Action
Fine
Status of proceedings
final
Sector
Construction and real estate
Liability of senior managers
Separate fine of 17,500 EUR against the managing director.
Published
9 Jan 2026

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16 Dec 2025 Hardeck Möbel GmbH & Co. KGFurniture retailer Hardeck: 379,503 EUR fine for breach of AML due diligence obligations GermanyCustomer due diligence €379,504

The Arnsberg regional government (Bezirksregierung Arnsberg), as anti-money laundering supervisor for the non-financial sector, imposed a fine of 379,503.50 EUR, final since 16 December 2025, on the furniture retailer as a dealer in goods for breach of due diligence obligations under the German Money Laundering Act (Geldwäschegesetz, GwG). Karl-Ernst Hardeck is named as the person responsible for the company.

What organisations can take from it

Furniture retailers, as dealers in goods, are also obliged entities under the GwG – breaches of due diligence obligations can trigger six-figure fines.

Relevance to training and awareness

Identification for cash payments in the trade in goods

Authority / court
Bezirksregierung Arnsberg (Geldwäscheaufsicht Nichtfinanzsektor)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Geldwäschegesetz (Sorgfaltspflichten); Bekanntmachung nach § 57 GwG
Action
Fine
Status of proceedings
final
Sector
Retail and e-commerce
Liability of senior managers
The announcement names Karl-Ernst Hardeck as the person responsible for the infringement

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16 Dec 2025 A AG / V-Konzern (in der amtlichen Mitteilung anonymisiert)BGH: fraud convictions of former managers in diesel scandal final GermanyEmissions and permits Custodial sentence

The Munich II Regional Court (Landgericht München II) had sentenced a head of department in diesel engine development and a former head of powertrain development for fraud in 94,924 cases to one year and nine months and two years respectively, and the former CEO of A AG for fraud in 17,177 cases to one year and nine months, in each case suspended on probation. They were responsible for unlawful defeat devices or failed to intervene despite having knowledge of them; the loss to buyers amounted to around 2.32 billion EUR. Germany's Federal Court of Justice (Bundesgerichtshof, BGH) dismissed the appeals on points of law (1 StR 270/24).

What organisations can take from it

Board members who learn of defeat devices and do not act commit a criminal offence themselves – indications of rule violations must immediately lead to investigation and information for customers.

Relevance to training and awareness

Dealing with non-compliant instructions in development and the duty to intervene

Authority / court
Bundesgerichtshof (1. Strafsenat); Vorinstanz Landgericht München II (Urteil vom 27.06.2023)
Area of law
Environment and sustainability · Emissions and permits
Legal basis
§ 263 StGB (Betrug); unzulässige Abschalteinrichtungen nach US- und EU-Zulassungsrecht
Action
Custodial sentence
Status of proceedings
final
Sector
Automotive
Culpability
intentional
Mitigating circumstances
Prison sentences suspended on probation in each case.
Liability of senior managers
Those convicted were a head of department (P.), a former head of powertrain development and later board member (H.), and the former CEO of A AG (S.), who took no action despite the serious possibility of further defeat devices.
Published
19 Dec 2025

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

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