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.

DACHSwitzerland Clear all filters
38cases from 1 jurisdiction
€556.1mTotal of monetary amounts (20 cases with an amount)
€143.3mLargest single case: Trafigura Beheer B.V.
€4.04mMedian per case with an amount

Click a bar to drill down one level.

Where?

by authority
  1. Bundesanwaltschaft (BA) €316.4m 57 % · 5 cases
  2. Bundesstrafgericht (Strafkammer); Anklage durch die Bundesanwaltschaft €143.3m 26 % · 1 case
  3. Wettbewerbskommission (WEKO) €55.6m 10 % · 10 cases
  4. Eidgenössische Finanzmarktaufsicht (FINMA) €27.5m 5 % · 12 cases
  5. Bundesanwaltschaft €10.1m 2 % · 4 cases
  6. Bundesstrafgericht (Strafkammer), Anklage der Bundesanwaltschaft €3.23m 1 % · 1 case
  7. Eidgenössischer Datenschutz- und Öffentlichkeitsbeauftragter (EDÖB) – 0 % · 4 cases
  8. Bundesverwaltungsgericht (A-3891/2025) auf Verfügung des EDÖB vom 28.04.2025 – 0 % · 1 case

What for?

by area of law

All areas of law

  1. Bribery and corruption €458.9m 83 % · 5 cases
  2. Competition law €55.6m 10 % · 10 cases
  3. Money laundering and terrorist financing €31.6m 6 % · 10 cases
  4. Capital markets and financial supervision €9.98m 2 % · 8 cases
  5. Data protection – 0 % · 5 cases

Who?

by sector

All sectors

  1. Energy and utilities €233.8m 42 % · 2 cases
  2. Steel and metals €138.9m 25 % · 1 case
  3. Other €82.3m 15 % · 2 cases
  4. Financial services and insurance €41.6m 7 % · 20 cases
  5. Retail and e-commerce €29.9m 5 % · 2 cases
  6. Telecoms, IT and software €19.4m 3 % · 2 cases
  7. Construction and real estate €5.37m 1 % · 3 cases
  8. Manufacturing and mechanical engineering €4.07m 1 % · 1 case
  9. Chemicals and pharmaceuticals €645,231 0 % · 1 case
  10. Transport, logistics and shipping €98,722 0 % · 2 cases
  11. 1 more€0

When?

per year, by date of decision
Trend
PeriodCasesTotal
20221€4.07m
20237€101.5m
202413€263.1m
202511€184.1m
20266€3.23m

38 cases

27 Jul 2026 Banque Lombard Odier & Cie SAFederal Criminal Court fines Banque Lombard Odier CHF 3 million over money laundering SwitzerlandInternal controls €3.23m

The Bundesstrafgericht (Federal Criminal Court) found Banque Lombard Odier & Cie SA guilty of failing to take adequate organisational measures against aggravated money laundering by a former relationship manager who in 2011 and 2012 handled accounts of a criminal organisation holding proceeds of corruption in the Uzbek telecommunications market; despite warning signs, the bank's anti-money-laundering functions did not sufficiently ensure that the origin and purpose of the funds were investigated and documented. The bank was fined CHF 3,000,000 and bears procedural costs of CHF 24,561.49; it was acquitted on the remaining charges, and proceedings for acts before 27 July 2011 were dismissed as time-barred. The judgment is not final.

What organisations can take from it

Warning signs about the origin of large inflows must be investigated and documented by the anti-money-laundering function itself, not just by the relationship manager.

Relevance to training and awareness

Anti-money-laundering: investigating conspicuous inflows and documentation

Authority / court
Bundesstrafgericht (Strafkammer), Anklage der Bundesanwaltschaft
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Art. 102 Abs. 2 StGB i.V.m. Art. 305bis Ziff. 1 und 2 StGB (Urteil SK.2023.42)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
The long time elapsed since the offences (2011/2012) was taken into account as mitigating.
Published
27 Jul 2026

Original amount 3,000,000 CHF, converted at the ECB reference rate of 27 Jul 2026.

Checked against the official source on 2 Oct 2026 · Direct link

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22 Jun 2026 Inkasso-Team AGFederal Administrative Court upholds FDPIC: Inkasso-Team was not allowed to publish debtor data SwitzerlandData subject rights and transparency Order

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.

What organisations can take from it

Publicly naming and shaming debtors cannot be justified under data protection law – debt collection must use less intrusive means.

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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3 Jun 2026 Wendelspiess Partners AG in LiquidationFINMA: Wendelspiess Partners breached FIDLEG duties, licence revoked SwitzerlandOrganisational requirements Order

Wendelspiess Partners AG invested almost all the money of its more than 400 clients in a barely diversified foreign fund it had set up and managed itself, which invested mainly in a Zug-based investment company and companies linked to it; it gave insufficient information about conflicts of interest and risks, carried out no suitability check and withheld relevant information from the Eidgenössische Finanzmarktaufsicht (FINMA, Swiss Financial Market Supervisory Authority). FINMA revoked the licence as an asset manager of the company, which is now bankrupt. Measures against individuals are not set out here. The decision is not final.

What organisations can take from it

In-house funds in client portfolios are a classic conflict of interest that must be disclosed and backed by a documented suitability check.

Relevance to training and awareness

Conflicts of interest with in-house funds; information and suitability duties

Authority / court
Eidgenössische Finanzmarktaufsicht (FINMA)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Verhaltenspflichten nach dem Finanzdienstleistungsgesetz (FIDLEG): Interessenkonflikte, Information, Eignungsprüfung; Auskunftspflicht gegenüber der FINMA
Action
Order
Status of proceedings
unknown
Sector
Financial services and insurance
Liability of senior managers
Measures against individuals are not set out here.
Published
3 Jun 2026

Checked against the official source on 5 Oct 2026 · Version 3 · Direct link

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1 May 2026 Swiss Fund Management AG in Liquidation; BZ Berater Zentrum AGFINMA revokes Swiss Fund Management's licence and confiscates BZ commissions SwitzerlandOrganisational requirements Order

Swiss Fund Management AG in liquidation and BZ Berater Zentrum AG, which held around 2,000 asset management mandates, channelled investor money of around CHF 200 million, directly or via funds, into illiquid bonds of interlinked issuers that financed real estate projects of related companies, without adequately informing investors about the conflicts of interest and without adequate suitability and appropriateness checks under FIDLEG (Swiss Financial Services Act). By ruling of 1 May 2026 the Eidgenössische Finanzmarktaufsicht (FINMA, Swiss Financial Market Supervisory Authority) revoked SFM's licence as a manager of collective assets, rejected BZ's application for a licence as an asset manager and confiscated placement commissions of more than CHF 3 million from BZ. The ruling is final.

What organisations can take from it

Anyone steering client money into products of related companies must disclose the conflicts of interest and document a suitability check for each client.

Relevance to training and awareness

Conflicts of interest and suitability checks in asset management

Authority / court
Eidgenössische Finanzmarktaufsicht (FINMA)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Verhaltensregeln nach dem Finanzdienstleistungsgesetz (FIDLEG): Interessenkonflikte, Eignungs- und Angemessenheitsprüfung
Action
Order
Status of proceedings
final
Sector
Financial services and insurance
Published
29 Jun 2026

Checked against the official source on 2 Oct 2026 · Direct link

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17 Apr 2026 Cream della Cream Switzerland GmbH und Philipp Plein International AGFDPIC ruling: Philipp Plein and Cream della Cream ignored objections to advertising SwitzerlandMarketing and consent Order

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.

What organisations can take from it

An objection to advertising must take effect across all systems – a confirmed deletion followed by further advertising violates the principle of good faith.

Relevance to training and awareness

Handling objections to advertising and deletion requests

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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27 Feb 2026 MBaer Merchant Bank AGFINMA withdraws MBaer Merchant Bank's licence over serious anti-money laundering deficiencies SwitzerlandInternal controls Order

Following enforcement proceedings, the Swiss Financial Market Supervisory Authority (FINMA) found serious, systematic deficiencies in anti-money laundering due diligence, organisation and risk management; the bank enabled clients to circumvent official asset freezes and executed transactions for sanctioned persons. FINMA had withdrawn the bank's licence and ordered its liquidation; with the withdrawal of the appeal before the Federal Administrative Court, the orders took effect on 27 February 2026. The day before, FinCEN had proposed designating the bank as an institution of primary money laundering concern.

What organisations can take from it

Systematic anti-money laundering and sanctions deficiencies can cost a bank its licence – not just money.

Authority / court
Eidgenössische Finanzmarktaufsicht (FINMA)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Schweizer Geldwäschereirecht und Bankenaufsichtsrecht (laut FINMA)
Action
Order
Status of proceedings
final
Sector
Financial services and insurance
Employees
50 to 249
Published
27 Feb 2026
Sources

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

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15 Dec 2025 Aktiengesellschaft Hallenstadion Zürich (AGH); Ticketcorner AGWEKO fines Hallenstadion Zurich and Ticketcorner over ticketing clause SwitzerlandAbuse of market power €122,929

At the end of 2008 Aktiengesellschaft Hallenstadion Zürich and Ticketcorner AG agreed that the arena would only be let to organisers selling at least 50% of tickets through Ticketcorner, which hindered other ticketing providers. After the Federal Supreme Court found a competition-law infringement in 2020 and remitted the case (2C_113/2017), the Wettbewerbskommission (WEKO, Swiss Competition Commission) classed both companies' conduct in 2009 to 2011 as abuse of a dominant position and, by decision of 15 December 2025, fined the Hallenstadion around CHF 50,000 and Ticketcorner around CHF 65,000. The arena operator had concluded an amicable settlement; the decision can be appealed to the Federal Administrative Court.

What organisations can take from it

Exclusivity clauses between strong market players remain a competition risk, even if the proceedings only end years later.

Relevance to training and awareness

Exclusivity clauses and tying by dominant undertakings

Authority / court
Wettbewerbskommission (WEKO)
Area of law
Competition law · Abuse of market power
Legal basis
Kartellgesetz (KG): Missbrauch einer marktbeherrschenden Stellung; Rückweisung BGer 2C_113/2017 vom 12.02.2020
Action
Fine
Status of proceedings
unknown
Sector
Other
Mitigating circumstances
The arena operator concluded an amicable settlement with WEKO.
Published
22 Jan 2026

Original amount 115,000 CHF, converted at the ECB reference rate of 15 Dec 2025.

Checked against the official source on 2 Oct 2026 · Direct link

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25 Aug 2025 PAUPE HOLDING SA, Bitusag S.A., Bitusag Neuchâtel SA, Wyss Fils SA, Prodo SA, Duckert SAWEKO fines road maintenance firms in Jura/Neuchâtel over bid rigging SwitzerlandCartels and collusion Fine

Regional suppliers of surface treatments and chip sealing in road maintenance colluded on bids and allocated territories. Switzerland's Competition Commission (Wettbewerbskommission, WEKO) imposed sanctions on Bitusag/Paupe (jointly and severally, CHF 640,000–990,000, exact amount redacted), Wyss Fils (CHF 44,000–74,000), Prodo (CHF 760) and Duckert (CHF 0) and approved amicable settlements; the investigation against Colas Suisse was discontinued.

What organisations can take from it

Small regional road builders are also sanctioned – cover bids and territorial protection must disappear from corporate culture.

Relevance to training and awareness

Cover bids and territorial agreements in regional road construction

Authority / court
Wettbewerbskommission (WEKO)
Area of law
Competition law · Cartels and collusion
Legal basis
Art. 5 Abs. 3 i.V.m. Abs. 1 KG, Art. 49a Abs. 1 KG
Action
Fine
Status of proceedings
unknown
Sector
Construction and real estate
Mitigating circumstances
Amicable settlements; leniency programme (Duckert free of sanctions)

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

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22 Aug 2025 Bank J. Safra Sarasin AGBank J. Safra Sarasin: 3.5 million CHF fine for money laundering in the Petrobras complex SwitzerlandInternal controls €3.73m

Between 2011 and 2014, the bank did not take all the necessary organisational precautions, with the result that bribes flowed to Petrobras executives through several account relationships (around 71 million USD in attempted or completed aggravated money laundering). Fine of 3.5 million CHF; because of a settlement of 16 million CHF with Petrobras, the Office of the Attorney General of Switzerland (Bundesanwaltschaft, OAG) waived a compensation claim.

What organisations can take from it

Unusual payment flows involving clients close to PEPs must be escalated and, if necessary, rejected – responsibility lies with the bank as an organisation.

Relevance to training and awareness

Anti-money laundering and PEP clients

Authority / court
Bundesanwaltschaft
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Art. 102 Abs. 2 StGB i. V. m. Art. 305bis Abs. 1 und 2 StGB
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Time elapsed since the offence, organisational corrective measures after the affair became known; no compensation claim because of the payment of 16 million CHF to Petrobras.
Published
22 Aug 2025

Original amount 3,500,000 CHF, converted at the ECB reference rate of 22 Aug 2025.

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

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22 Aug 2025 J.P. Morgan (Suisse) SAJ.P. Morgan (Suisse): 3 million CHF fine in the 1MDB complex for deficient anti-money laundering controls SwitzerlandCustomer due diligence €3.2m

Between October 2014 and July 2015, around 174 million CHF from predicate offences in the 1MDB complex passed through the bank in 43 transfers, even though negative information about the Petrosaudi managers involved was publicly available. The Office of the Attorney General of Switzerland (Bundesanwaltschaft) convicted the bank by summary penalty order and imposed 3 million CHF; a compensation claim was waived because the 1MDB fund is being compensated as a private claimant.

What organisations can take from it

Publicly available negative information about clients must feed into the risk assessment and be capable of stopping transactions.

Relevance to training and awareness

Customer due diligence and adverse media screening

Authority / court
Bundesanwaltschaft
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Art. 102 Abs. 2 StGB i. V. m. Art. 305bis Abs. 1 und 2 StGB
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Time elapsed since the offence, very good cooperation in the proceedings, compensation of the private claimant (1MDB).
Published
22 Aug 2025

Original amount 3,000,000 CHF, converted at the ECB reference rate of 22 Aug 2025.

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

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8 Jul 2025 Markant Handels- und Industriewaren-Vermittlungs AG und 16 Händlerinnen (in der Quelle nicht namentlich genannt)WEKO fines 16 retailers in the Markant buying cooperation around CHF 28 million SwitzerlandCartels and collusion €29.9m

The Wettbewerbskommission (WEKO, Swiss Competition Commission) found discounts negotiated jointly through the Markant cooperation to be lawful, but not opaque rebates: suppliers had to buy an ever more expensive service package from Markant, part of whose fees Markant passed on undisclosed to 16 retailers, and suppliers who refused faced collective countermeasures up to delisting. WEKO classed this as an unlawful purchasing-side price agreement and fined the 16 retailers a total of around CHF 28 million. The decision can be appealed to the Federal Administrative Court.

What organisations can take from it

Buying cooperations may pool negotiating power, but payments to members must be disclosed to suppliers and must not be enforced through collective pressure.

Relevance to training and awareness

Buying cooperations in retail: limits of joint negotiating power

Authority / court
Wettbewerbskommission (WEKO)
Area of law
Competition law · Cartels and collusion
Legal basis
Kartellgesetz (KG): unzulässige einkaufsseitige Preisabrede
Action
Fine
Status of proceedings
unknown
Sector
Retail and e-commerce
Published
8 Jul 2025

Original amount 28,000,000 CHF, converted at the ECB reference rate of 8 Jul 2025.

Checked against the official source on 2 Oct 2026 · Direct link

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17 Jun 2025 Banque Pictet et Cie SABanque Pictet: 2 million CHF fine for laundering Petrobras bribes SwitzerlandInternal controls €2.13m

Between 2010 and 2013, 54 transfers were processed through the bank by which bribes of around 4.1 million USD connected with SBM Offshore's charter contracts with Petrobras were concealed. The bank had not classified high-risk accounts as such and had inadequately monitored transfers; the Office of the Attorney General of Switzerland (Bundesanwaltschaft) imposed a fine of 2 million CHF on the bank.

What organisations can take from it

Risk classification and transaction monitoring must take effect before individual relationship managers approve payments.

Relevance to training and awareness

High-risk clients and transaction monitoring

Authority / court
Bundesanwaltschaft
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Art. 102 Abs. 2 StGB i. V. m. Art. 305bis und Art. 322septies StGB
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Time elapsed since the offence, very good cooperation, organisational corrective measures after the Petrobras affair became known.
Published
17 Jun 2025

Original amount 2,000,000 CHF, converted at the ECB reference rate of 17 Jun 2025.

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

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16 May 2025 PostFinance AGEDÖB orders PostFinance to obtain explicit consent for voice recognition SwitzerlandData subject rights and transparency Order

PostFinance AG created voiceprints of its customers for authentication by voice recognition without obtaining their active consent; customers who did not want this had to object themselves. The Eidgenössischer Datenschutz- und Öffentlichkeitsbeauftragter (EDÖB, Federal Data Protection and Information Commissioner) considered this processing of biometric data disproportionate and, by ruling of 16 May 2025, ordered PostFinance to obtain explicit consent in future and to delete voiceprints for which no such consent exists. PostFinance has appealed to the Federal Administrative Court.

What organisations can take from it

Biometric procedures need an active opt-in from the individuals concerned; a mere right to object is not enough.

Relevance to training and awareness

Biometric authentication and consent (opt-in instead of opt-out)

Authority / court
Eidgenössischer Datenschutz- und Öffentlichkeitsbeauftragter (EDÖB)
Area of law
Data protection · Data subject rights and transparency
Legal basis
Bundesgesetz über den Datenschutz (DSG): Grundsatz der Verhältnismässigkeit; biometrische Daten als besonders schützenswerte Personendaten, ausdrückliche Einwilligung
Action
Order
Status of proceedings
under appeal
Sector
Financial services and insurance
Published
7 Aug 2025

Checked against the official source on 2 Oct 2026 · Direct link

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10 Apr 2025 Boehringer Ingelheim, Alkaloids of Australia, C2 PHARMA u. a. (7 Unternehmen)WEKO sanctions active-ingredient cartel over butylscopolamine bromide at around CHF 600,000 SwitzerlandCartels and collusion €645,231

Between 2005 and 2019 Boehringer Ingelheim, Alkaloids of Australia, Alkaloids Corporation, Alchem, C2 PHARMA, Linnea and Transo-Pharm set minimum selling prices for the active ingredient butylscopolamine bromide (SNBB), allocated quotas and exchanged sensitive business information. The Wettbewerbskommission (WEKO, Swiss Competition Commission) closed the case with amicable settlements; sanctions total around CHF 600,000, with C2 PHARMA as the self-reporting party exempted in full and Transo-Pharm and Linnea in part. It is the first cartel concerning a pharmaceutical active ingredient that WEKO has sanctioned.

What organisations can take from it

Even small niche markets for intermediate products are watched by competition authorities, and the first to report can escape the sanction entirely.

Relevance to training and awareness

Cartel risks for intermediate products and active ingredients; leniency programme

Authority / court
Wettbewerbskommission (WEKO)
Area of law
Competition law · Cartels and collusion
Legal basis
Kartellgesetz (KG): Preis- und Mengenabrede, einvernehmliche Regelungen, Bonusregelung
Action
Fine
Status of proceedings
unknown
Sector
Chemicals and pharmaceuticals
Mitigating circumstances
Amicable settlements; full immunity for C2 PHARMA (leniency programme), partial reduction for Transo-Pharm and Linnea.
Published
10 Apr 2025

Original amount 600,000 CHF, converted at the ECB reference rate of 10 Apr 2025.

Checked against the official source on 2 Oct 2026 · Direct link

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27 Feb 2025 Morgan Stanley (Switzerland) GmbHMorgan Stanley (Switzerland): 1 million CHF fine for organisational deficiency in money laundering case SwitzerlandInternal controls €1.06m

In 2010, the company's legal predecessor did not take all necessary and reasonable organisational precautions to prevent a relationship manager from committing aggravated money laundering with assets derived from bribery offences in Greece. The Office of the Attorney General of Switzerland (Bundesanwaltschaft) concluded the proceedings with a summary penalty order of 1 million CHF.

What organisations can take from it

Under corporate criminal law, organisational deficiencies do not become time-barred when the employee leaves – controls must be demonstrably effective.

Authority / court
Bundesanwaltschaft
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Art. 102 Abs. 2 StGB i. V. m. Art. 305bis StGB
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
27 Feb 2025

Original amount 1,000,000 CHF, converted at the ECB reference rate of 27 Feb 2025.

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

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31 Jan 2025 Trafigura Beheer B.V.Swiss Federal Criminal Court (Bundesstrafgericht) convicts Trafigura of bribery in Angola SwitzerlandBribery of public officials €143.3m

Between 2009 and 2011, more than 4 million EUR and more than 600,000 USD were paid to an official in Angola 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). It was the first judgment of the Federal Criminal Court on corporate criminal liability for foreign bribery; it is not final.

What organisations can take from it

In Switzerland, companies are liable if their organisation fails to prevent bribery – and the compensatory claim can exceed the fine many times over.

Relevance to training and awareness

Payments via intermediaries to employees of state-owned oil companies

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
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 28 Sep 2026 · Version 3 · Direct link

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29 Jan 2025 Cembra Money Bank AGFDPIC ruling: Cembra Money Bank answered access requests too late and in generic terms SwitzerlandData subject rights and transparency Order

From December 2023 to September 2024, Cembra answered 9 of 13 access requests after the 30-day deadline had expired, and responded to all 13 people only with standard letters instead of the data actually processed about them. The Swiss Federal Data Protection and Information Commissioner (Eidgenössischer Datenschutz- und Öffentlichkeitsbeauftragter, EDÖB) required the bank to provide the data subsequently.

What organisations can take from it

Access requests need a process with resources and deadline monitoring – boilerplate text is no substitute for genuine disclosure of data.

Relevance to training and awareness

Handling access requests

Authority / court
Eidgenössischer Datenschutz- und Öffentlichkeitsbeauftragter (EDÖB)
Area of law
Data protection · Data subject rights and transparency
Legal basis
DSG Art. 25 Abs. 2 lit. b, Art. 25 Abs. 7
Action
Order
Status of proceedings
final
Sector
Financial services and insurance
Published
1 Jul 2025

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

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12 Dec 2024 Leonteq AG (Finanzgruppe Leonteq)Leonteq: distribution via unregulated partners – confiscation of 9.3 million CHF in profits SwitzerlandOrganisational requirements €9.98m

The Swiss Financial Market Supervisory Authority (FINMA) found serious breaches of risk management obligations and of the requirement to guarantee irreproachable business conduct: the financial group monitored its distribution chain inadequately and in some cases worked with dubious, unregulated distributors that sold products in countries not intended for them without authorisation. FINMA ordered governance requirements, the termination of these relationships, the appointment of an audit agent and the confiscation of 9.3 million CHF in profits; the ruling was not yet final at the time of publication.

What organisations can take from it

Anyone who distributes via third parties is liable for their regulatory status – sales partners require due diligence just like customers.

Authority / court
Eidgenössische Finanzmarktaufsicht (FINMA)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Finanzmarktaufsichtsgesetz (FINMAG)
Action
Disgorgement of profits
Status of proceedings
unknown
Sector
Financial services and insurance
Mitigating circumstances
Good cooperation in the proceedings; Leonteq had already strengthened compliance and distribution controls of its own accord and terminated relationships with suspicious distributors

Original amount 9,300,000 CHF, converted at the ECB reference rate of 12 Dec 2024.

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23 Sep 2024 a French publishing groupWEKO orders a French publishing group to grant a Swiss bookseller domestic terms (under appeal) SwitzerlandAbuse of market poweranonymised Order

A French publishing group charged a Swiss bookseller considerably higher purchase prices for direct supply in France than are customary there, although the bookseller had no reasonable alternatives. The Swiss Competition Commission (WEKO) found an abuse of relative market power and ordered the publishing group to grant the bookseller the sales and discount terms applicable in France for direct purchases, less admissible additional costs for the Swiss market; the publishing group bears the procedural costs of CHF 254,865. According to WEKO (as of March 2025), an appeal against the decision was pending before the Federal Administrative Court.

What organisations can take from it

Since relative market power was introduced, foreign suppliers can also be required to grant dependent Swiss buyers their domestic terms.

Relevance to training and awareness

Relative market power and refusal to supply on foreign terms

Authority / court
Wettbewerbskommission (WEKO)
Area of law
Competition law · Abuse of market power
Legal basis
Art. 7 Abs. 1 und 2 lit. g KG (relative Marktmacht), Art. 30 Abs. 1 KG
Action
Order
Status of proceedings
under appeal
Sector
Media and online platforms
Published
21 Nov 2024

Checked against the official source on 2 Oct 2026 · Company name anonymised since 23 Sep 2026 · Direct link

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17 Sep 2024 a Swiss private bankFINMA: private bank seriously breached AML duties, CHF 12.7 million confiscated SwitzerlandCustomer due diligenceanonymised €13.5m

The Eidgenössische Finanzmarktaufsicht (FINMA, Swiss Financial Market Supervisory Authority) found that the bank, despite warnings, inadequately checked and documented beneficial ownership and the background of transactions in business relationships with complex structures possibly attributable to a now-deceased businessman accused of tax evasion, which at times held up to USD 1.7 billion. FINMA confiscated CHF 12.7 million of unlawfully earned profits, prohibited the bank from taking on new clients with increased money-laundering risks until compliance is restored, ordered a review of all client relationships and of higher-risk transactions from 2018 to 2022, and appointed an audit agent. The ruling issued in June 2023 has been final since August 2023.

What organisations can take from it

Since aggravated tax offences count as predicate offences, banks must investigate tax-risk warning signs just like other money-laundering risks.

Relevance to training and awareness

Aggravated tax offences as a predicate offence to money laundering; duty to investigate

Authority / court
Eidgenössische Finanzmarktaufsicht (FINMA)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Finanzmarktaufsichtsrecht: Geldwäschereiprävention, angemessene Organisation und Risikomanagement (Einziehung zugunsten der Staatskasse)
Action
Disgorgement of profits
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
The bank cooperated in the proceedings and took its own organisational, operational and personnel measures during the proceedings.
Liability of senior managers
FINMA opened three enforcement proceedings against individuals.
Published
17 Sep 2024

Original amount 12,700,000 CHF, converted at the ECB reference rate of 17 Sep 2024.

Sources

Checked against the official source on 2 Oct 2026 · Company name anonymised since 17 Sep 2026 · Direct link

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