Who was sanctioned, and for what?

Between 2009 and 2011, more than 4 million EUR and more than 600,000 USD were paid to a senior employee of the Angolan state oil distributor in order to promote ship chartering and bunkering business of the Trafigura group. The court convicted the then parent company for lacking rules on the supervision of intermediaries, imposing a fine of 3 million CHF and a compensatory claim (Ersatzforderung) of 145,634,268 USD (amount converted at the ECB rate of 31 January 2025: 148,933,982 USD in total); three individuals received prison sentences. It was the first judgment of the Federal Criminal Court on corporate criminal liability for foreign bribery; it is not final.

Authority / court

Bundesstrafgericht (Strafkammer); Anklage durch die Bundesanwaltschaft

Area of law

Bribery and corruption · Bribery of public officials

Legal basis

Art. 102 StGB i. V. m. Art. 322septies StGB (Bestechung fremder Amtsträger); SK.2023.49

Action

Fine

Status of proceedings

unknown

Sector

Energy and utilities

Employees

10,000 or more

Culpability

intentional

Liability of senior managers

A former senior manager of the group received a prison sentence of 32 months (12 of them unsuspended), the intermediary 24 months suspended, and the Angolan public official 36 months (names anonymised).

Published

31 Jan 2025

Original amount 148,933,982 USD, converted at the ECB reference rate of 31 Jan 2025.

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

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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.

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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From December 2022, an auditor and tax adviser processed payments of another limited company totalling around 1.26 million EUR through the bank account of his tax advisory company, which was held as an own account, without disclosing this to the bank – according to the court, deliberately in order to avoid a compliance review. The Austrian Federal Administrative Court (Bundesverwaltungsgericht, BVwG) upheld the fine of 30,000 EUR imposed on him by the Financial Market Authority (Finanzmarktaufsicht, FMA) in its penalty decision of 27 November 2025, in his capacity as managing director of the account-holding company, which is liable for the penalty; an ordinary appeal on points of law is not admissible.

Authority / court

Bundesverwaltungsgericht (BVwG); Straferkenntnis der Finanzmarktaufsicht (FMA) vom 27.11.2025

Area of law

Money laundering and terrorist financing · Customer due diligence

Legal basis

§ 6 Abs. 3 FM-GwG (Offenlegung des Handelns auf fremde Rechnung) i. V. m. § 34 Abs. 5 FM-GwG; § 9 Abs. 1 und 7 VStG

Action

Fine

Status of proceedings

final

Sector

Other

Culpability

intentional

Liability of senior managers

Fine imposed on the managing director personally; liability of the company under Section 9(7) VStG (Austrian Administrative Penal Act)

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

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On 29 May 2024, the Vienna broadcaster W24 aired advertising in split screen within the programme ‘24 Stunden Wien’, did not adequately separate advertising from programming and, at around 50 minutes, significantly exceeded the permitted 12 minutes of advertising per hour. The Austrian Communications Authority (Kommunikationsbehörde Austria, KommAustria) imposed fines totalling 500 EUR (plus 50 EUR in costs) on the body authorised to represent the company externally; the GmbH is jointly and severally liable under § 9 (7) VStG (Austrian Administrative Penal Act).

Authority / court

Kommunikationsbehörde Austria (KommAustria)

Area of law

Consumer protection and online retail · Misleading advertising and pricing

Legal basis

§ 64 Abs. 2 Z 9 i. V. m. §§ 43 Abs. 2, 44 Abs. 1, 45 Abs. 1 AMD-G; § 9 VStG

Action

Fine

Status of proceedings

final

Sector

Media and online platforms

Culpability

negligent

Mitigating circumstances

No previous record, duration of proceedings, remorseful confession and remedial measures initiated.

Liability of senior managers

Fine imposed on the body responsible externally (§ 9 (1) VStG); the company is jointly and severally liable.

Published

19 Aug 2026

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

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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).

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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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.

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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In the programme ‘Sport aktuell’ on ORF 1 on 29 July 2025, a logo wall was visible as product placement without being labelled. The Austrian Communications Authority (Kommunikationsbehörde Austria, KommAustria) found, with final effect, a violation of the ORF Act (ORF-Gesetz).

Authority / court

Kommunikationsbehörde Austria (KommAustria)

Area of law

Consumer protection and online retail · Misleading advertising and pricing

Legal basis

§ 16 Abs. 5 Z 4 ORF-G

Action

Order

Status of proceedings

final

Sector

Media and online platforms

Published

29 Jul 2026

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

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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.

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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The managing director under commercial law of a GmbH (anonymised in the decision as ‘L GmbH’, insolvent in 2025) had underpaid twelve employees by considerable amounts, partly in 2023 and predominantly in 2024. The Vienna municipal authority (Magistrat der Stadt Wien) imposed 38,000 EUR, and the Vienna Administrative Court (Verwaltungsgericht Wien) reduced this to 15,000 EUR; Austria's Supreme Administrative Court (Verwaltungsgerichtshof, VwGH) rejected the appeal on points of law (Ra 2026/11/0064).

Authority / court

Verwaltungsgerichtshof (Vorinstanzen: Magistrat der Stadt Wien, Verwaltungsgericht Wien)

Area of law

Health and safety and employment law · Minimum wage and undeclared work

Legal basis

§ 29 Abs. 1 Lohn- und Sozialdumping-Bekämpfungsgesetz (LSD-BG)

Action

Fine

Status of proceedings

reduced

Mitigating circumstances

Reduction of the fine by the Vienna Administrative Court.

Liability of senior managers

The fine is directed against the managing director under commercial law.

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

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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.

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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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.

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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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.

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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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.

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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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.

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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The company had stored statistically calculated ‘party affinities’ for around 2.2 million people and in some cases sold them to advertising clients – special categories of personal data without consent; in addition, parcel frequency data was further processed for incompatible purposes. The Austrian Data Protection Authority (Datenschutzbehörde, DSB) had imposed 18 million EUR in 2019 and the Federal Administrative Court (Bundesverwaltungsgericht, BVwG) 16 million EUR in 2024; Austria's Supreme Administrative Court (Verwaltungsgerichtshof, VwGH) has now set the fine with final effect at 13 million EUR (plus 100,000 EUR in procedural costs).

Authority / court

Verwaltungsgerichtshof (Ausgangsbescheid: Datenschutzbehörde)

Area of law

Data protection · Marketing and consent

Legal basis

DSGVO Art. 5 Abs. 1 lit. a und b, Art. 6 Abs. 4, Art. 9 Abs. 1 (VwGH Ro 2025/04/0007)

Action

Fine

Status of proceedings

reduced

Sector

Other

Culpability

negligent

Mitigating circumstances

Comprehensive cooperation, deletion of the party affinities, settlements with data subjects, long duration of proceedings (5 years, 10 months).

Published

16 Jul 2026

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

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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.

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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The debt collection company posted personal data of alleged debtors on the internet, some of it particularly sensitive, in order to obtain information on their whereabouts and to warn third parties. The Swiss Federal Administrative Court (Bundesverwaltungsgericht, A-3891/2025) upheld the ruling of the Federal Data Protection and Information Commissioner (EDÖB) of 28 April 2025, according to which this constitutes an unjustified violation of privacy.

Authority / court

Bundesverwaltungsgericht (A-3891/2025) auf Verfügung des EDÖB vom 28.04.2025

Area of law

Data protection · Data subject rights and transparency

Legal basis

DSG Art. 6, Art. 19, Art. 31

Action

Order

Status of proceedings

final

Sector

Financial services and insurance

Published

20 Aug 2026

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

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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.

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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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.

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

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

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Both companies continued to use e-mail addresses and telephone numbers from online purchases for advertising, although data subjects had objected – in some cases after deletion had been confirmed. The Swiss Federal Data Protection and Information Commissioner (Eidgenössischer Datenschutz- und Öffentlichkeitsbeauftragter, EDÖB) ordered the processing for advertising to cease and the data to be deleted on request.

Authority / court

Eidgenössischer Datenschutz- und Öffentlichkeitsbeauftragter (EDÖB)

Area of law

Data protection · Marketing and consent

Legal basis

DSG Art. 6, Art. 30 Abs. 2 lit. b, Art. 31

Action

Order

Status of proceedings

final

Sector

Retail and e-commerce

Published

26 Jun 2026

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

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