Who was sanctioned, and for what?

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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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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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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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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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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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.

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

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

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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).

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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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).

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

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

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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.

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

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

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Two employers remunerated part-time workers solely by providing a company car. Germany's Federal Social Court (Bundessozialgericht, BSG) upheld the German pension insurance's claims for additional contributions: the benefit in kind does not satisfy the minimum wage entitlement, and contributions must be paid on the minimum wage owed (B 12 BA 8/24 R, B 12 BA 6/23 R).

Authority / court

Bundessozialgericht, 12. Senat (Betriebsprüfung: Deutsche Rentenversicherung Bund)

Area of law

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

Legal basis

§ 1 MiLoG; § 28p SGB IV (Betriebsprüfung)

Action

Order

Status of proceedings

final

Published

14 Nov 2025

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

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By decision of 28 October 2025 (final since 7 November 2025), Germany's Federal Financial Supervisory Authority (BaFin) imposed a fine of 20,000 EUR because, from October 2022 to September 2023, the Landesbank operated data processing systems for money laundering prevention that were only partially adequate. Under the German Banking Act (KWG), the criteria by which monitoring identifies suspicious transactions must be documented, and the systems must be checked regularly by an independent auditor.

Authority / court

Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)

Area of law

Money laundering and terrorist financing · Internal controls

Legal basis

§ 56 Abs. 2 Nr. 11b KWG (Betrieb angemessener Datenverarbeitungssysteme zur Geldwäscheprävention)

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Published

10 Dec 2025

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

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By decision of 13 October 2025 (final since 30 October 2025), Germany's Federal Financial Supervisory Authority (BaFin) imposed a fine of 45 million EUR on J.P. Morgan SE because the institution had culpably breached its duty of supervision in the internal processes for filing money laundering suspicious activity reports; from 4 October 2021 to 30 September 2022, suspicious activity reports were systematically not filed on time. BaFin points out that, in the case of systematic infringements, the amount of the fine can be based on the institution's total turnover.

Authority / court

Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)

Area of law

Money laundering and terrorist financing · Suspicious activity reports

Legal basis

§ 130 Abs. 1 OWiG (Aufsichtspflichtverletzung) i. V. m. Pflichten nach dem GwG (Verdachtsmeldungen); Bekanntmachung nach § 57 Abs. 1 GwG

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Employees

10,000 or more

Published

6 Nov 2025

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

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A food discounter advertised a coffee with a price reduction without stating the lowest total price of the previous 30 days unambiguously, clearly recognisably and legibly. In an action brought by the Wettbewerbszentrale (Centre for Protection against Unfair Competition), the BGH upheld the injunction issued by the lower courts (Regional Court of Amberg, Higher Regional Court of Nuremberg).

Authority / court

Bundesgerichtshof (I. Zivilsenat), Az. I ZR 183/24

Area of law

Consumer protection and online retail · Misleading advertising and pricing

Legal basis

§ 11 Abs. 1 PAngV; § 5a Abs. 1, § 5b Abs. 4 UWG

Action

Order

Status of proceedings

final

Sector

Retail and e-commerce

Published

9 Oct 2025

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

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A retail company (name not published) had advertising letters sent via service providers and, in several cases, failed for an extended period to respond in time to the data subject rights that recipients then asserted. The Hamburg Commissioner for Data Protection and Freedom of Information (HmbBfDI) imposed a fine of 195,000 EUR; the measure was published in the interim report of 30 September 2025 (exact date of the decision not stated).

Authority / court

Hamburgischer Beauftragter für Datenschutz und Informationsfreiheit (HmbBfDI)

Area of law

Data protection · Data subject rights and transparency

Legal basis

DSGVO (Betroffenenrechte)

Action

Fine

Status of proceedings

unknown

Sector

Retail and e-commerce

Published

30 Sep 2025

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

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By decision of 22 August 2025, Germany's Federal Financial Supervisory Authority (BaFin) imposed a fine of 3.3 million EUR because the bank systematically filed suspicious activity reports late from June 2023 to March 2025; in February 2025, a penalty payment of 500,000 EUR had already been imposed for failure to comply with a 2023 order concerning Iran-related transactions (total 3.8 million EUR). In addition, in July 2025 BaFin ordered comprehensive remediation of the deficiencies in money laundering prevention, with an action plan and reporting obligations.

Authority / court

Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)

Area of law

Money laundering and terrorist financing · Suspicious activity reports

Legal basis

Bußgeld: § 56 Abs. 1 S. 1 Nr. 69, Abs. 3 GwG; Anordnung: § 51 Abs. 2 GwG, § 44 Abs. 1 KWG; Zwangsgeld: § 14 VwVG i. V. m. § 17 FinDAG; Bekanntmachung nach § 57 Abs. 1 GwG

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Repeat case

yes

Published

16 Sep 2025

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

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A practice for aesthetic treatments advertised hyaluronic acid filler injections for the nose and chin on its website and on Instagram using before-and-after images. In an action brought by a consumer advice centre (Verbraucherzentrale), the BGH upheld the injunction issued by the Higher Regional Court of Hamm (OLG Hamm): such procedures are deemed to be surgical cosmetic procedures, for which this kind of advertising is prohibited.

Authority / court

Bundesgerichtshof (I. Zivilsenat), Az. I ZR 170/24

Area of law

Consumer protection and online retail · Misleading advertising and pricing

Legal basis

§ 11 Abs. 1 Satz 3 Nr. 1, § 1 Abs. 1 Nr. 2 Buchst. c HWG; UKlaG

Action

Order

Status of proceedings

final

Sector

Healthcare

Published

31 Jul 2025

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

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The Saxony State Directorate (Landesdirektion Sachsen), as anti-money laundering supervisor for the non-financial sector, imposed a fine of 7,000 EUR on an art dealer, announced in anonymised form, for breaches of the due diligence obligations and risk management requirements under the German Money Laundering Act (GwG). The authority had previously issued several orders on risk management in the art trade, backed by the threat of penalty payments.

Authority / court

Landesdirektion Sachsen (Geldwäscheaufsicht Nichtfinanzsektor)

Area of law

Money laundering and terrorist financing · Internal controls

Legal basis

Geldwäschegesetz (Sorgfaltspflichten, Risikomanagement); Bekanntmachung nach § 57 GwG

Action

Fine

Status of proceedings

final

Sector

Retail and e-commerce

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

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Malicious employees in partner agencies that broker contracts for Vodafone had created fictitious contracts and contract changes to the detriment of customers. The German Federal Commissioner for Data Protection and Freedom of Information (BfDI) imposed 15 million EUR for inadequate vetting and monitoring of the partner agencies (Art. 28) and 30 million EUR for authentication deficiencies in ‘MeinVodafone’ in combination with the hotline, through which unauthorised persons were able, among other things, to retrieve eSIM profiles; in addition, a reprimand was issued under Art. 32.

Authority / court

Bundesbeauftragte für den Datenschutz und die Informationsfreiheit (BfDI)

Area of law

Data protection · Data processors

Legal basis

Art. 28 Abs. 1 S. 1, Art. 32 Abs. 1 DSGVO

Action

Fine

Status of proceedings

final

Sector

Telecoms, IT and software

Mitigating circumstances

Full cooperation including self-incrimination, modernisation of systems, separation from fraudulent partners; fines accepted and paid, plus donations amounting to millions.

Published

3 Jun 2025

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

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SAP had not published an announcement stating from when and at which internet address the 2022 annual financial report was publicly available in addition to the company register (Hinweisbekanntmachung). BaFin imposed a fine of 1.75 million 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

§ 114 Abs. 1 Satz 2 WpHG

Action

Fine

Status of proceedings

final

Sector

Telecoms, IT and software

Published

27 May 2025

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

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From 2016 to 2019, seven road repair companies allocated contracting authorities regionally, determined in advance who should win the contract and set each other minimum prices for cover bids. The Bundeskartellamt imposed fines of 10.5 million EUR; BITUNOVA cooperated as leniency applicant, and all proceedings ended in settlements. Addressees: AS Asphaltstraßensanierung GmbH, bausion Strassenbau-Produkte GmbH, BITUNOVA GmbH, Gerhard Herbers GmbH, Liesen … alles für den Bau GmbH, Mainka GmbH Straßenunterhaltung, MOT Müritzer Oberflächentechnik GmbH.

Authority / court

Bundeskartellamt

Area of law

Competition law · Cartels and collusion

Legal basis

§ 1 GWB

Action

Fine

Status of proceedings

final

Sector

Construction and real estate

Mitigating circumstances

Leniency programme (BITUNOVA), settlement

Liability of senior managers

Criminal prosecution of the individuals involved by the Düsseldorf public prosecutor's office

Published

13 May 2025

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

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Since at least 2015, Sennheiser coordinated consumer prices for premium headphones with dealers, monitored them using price comparison services and specialist software and intervened when prices were too low; Sonova continued this after acquiring the business unit in March 2022 until September 2022. The employees had received competition law training but used this knowledge to conceal their conduct (code language). The Bundeskartellamt imposed fines of almost 6 million EUR on both companies and three responsible employees (settlement).

Authority / court

Bundeskartellamt

Area of law

Competition law · Cartels and collusion

Legal basis

§ 1 GWB (vertikale Preisbindung)

Action

Fine

Status of proceedings

final

Sector

Retail and e-commerce

Mitigating circumstances

Extensive cooperation and settlement

Liability of senior managers

Fines imposed on three responsible employees (not named)

Published

7 May 2025

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

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From March 2021, a machinery manufacturer from the Rhein-Neckar district is alleged to have declared steel products worth more than 2.9 million EUR as being of British origin in more than 100 customs clearances, although the steel came from India and was only imported via the UK; correctly, 25% higher import duties would have been payable. In December 2024, the Stuttgart customs investigation office (Zollfahndungsamt Stuttgart), acting on behalf of the European Public Prosecutor's Office (EPPO), searched business premises in Germany and at the British seller; the damage is estimated at several hundred thousand euros.

Authority / court

Zollfahndungsamt Stuttgart im Auftrag der Europäischen Staatsanwaltschaft (EPPO)

Area of law

Sanctions and export control · Customs

Legal basis

Verdacht der Steuerhinterziehung (Einfuhrabgaben nach EU-Zollrecht, falsche Ursprungsangaben)

Action

Incident without known action

Status of proceedings

unknown

Sector

Steel and metals

Published

3 Feb 2025

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

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The Saxony State Directorate (Landesdirektion Sachsen), as anti-money laundering supervisor for the non-financial sector, imposed a fine of 800 EUR on an estate agent, announced in anonymised form, for breach of the due diligence obligations under the German Money Laundering Act (GwG). The list of announcements shows numerous further fines and reprimands against agents ranging from 50 to 5,000 EUR.

Authority / court

Landesdirektion Sachsen (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

Construction and real estate

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

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In April 2021, data on around 533 million Facebook users from 106 countries was made public, which unknown persons had previously linked to telephone numbers and harvested via the contact import function. Germany's Federal Court of Justice (Bundesgerichtshof, BGH) ruled that the mere loss of control over data already constitutes non-material damage under Art. 82 GDPR, considered around 100 EUR appropriate and referred the case back to the Higher Regional Court of Cologne (OLG Köln), among other things to examine the default searchability setting in the light of data minimisation.

Authority / court

Bundesgerichtshof (VI. Zivilsenat)

Area of law

Data protection · Data breaches and data security

Legal basis

Art. 82 Abs. 1 DSGVO

Action

Other

Status of proceedings

unknown

Sector

Media and online platforms

Employees

10,000 or more

Published

18 Nov 2024

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

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In 2015, despite the Russia embargo, the 56-year-old managing director of a Baden-Württemberg machine tool company and a Swiss holding company supplied six machine tools with accessories to a Russian arms manufacturer for the series production of sniper rifles, and concealed the recipient and intended use. The 2nd Criminal Division of the Stuttgart Higher Regional Court (Oberlandesgericht Stuttgart, Ref. 2 St 3 BJs 48/22) imposed an aggregate sentence of seven years' imprisonment; around 3 million EUR was confiscated from the holding company and 2.1 million EUR from the defendant (of which 674,000 EUR jointly and severally). Not final.

Authority / court

Oberlandesgericht Stuttgart, 2. Strafsenat (Az. 2 St 3 BJs 48/22)

Area of law

Sanctions and export control · Breaches of sanctions and embargoes

Legal basis

§§ 17, 18 Außenwirtschaftsgesetz i. V. m. Beschluss 2014/512/GASP und Verordnung (EU) Nr. 833/2014

Action

Custodial sentence

Status of proceedings

unknown

Sector

Manufacturing and mechanical engineering

Culpability

intentional

Liability of senior managers

Managing director personally sentenced to seven years' imprisonment.

Published

7 Nov 2024

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

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In the tender for the refurbishment of the Zoobrücke bridge in Cologne in early 2017, employees agreed that one company would submit a cover bid so that the other would win the contract, in return for a later compensation payment. Strabag received a fine of 2.79 million EUR (settlement); the proceedings against Kemna were discontinued as it was the leniency applicant.

Authority / court

Bundeskartellamt

Area of law

Competition law · Cartels and collusion

Legal basis

§ 1 GWB

Action

Fine

Status of proceedings

final

Sector

Construction and real estate

Employees

10,000 or more

Mitigating circumstances

Settlement

Liability of senior managers

The Cologne public prosecutor's office is prosecuting the individuals involved under Section 298 StGB (German Criminal Code)

Published

6 Nov 2024

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

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A manufacturer of fruit gums and liquorice (not named in the official press release) advertised in a trade journal that it had produced all its products ‘climate neutral’ since 2021, although this was achieved partly through offsetting. Germany's Federal Court of Justice (Bundesgerichtshof, BGH) prohibited the advertising following an action brought by the Centre for Protection against Unfair Competition (Wettbewerbszentrale): ambiguous environmental terms must be explained in the advertisement itself, since reduction and offsetting are not equivalent.

Authority / court

Bundesgerichtshof (I. Zivilsenat)

Area of law

Environment and sustainability · Misleading environmental and sustainability claims

Legal basis

§ 3 Abs. 1, § 5 Abs. 1, § 5a Abs. 1 und 3, § 8 Abs. 1 Satz 1 UWG (Az. I ZR 98/23)

Action

Order

Status of proceedings

final

Sector

Food and agriculture

Published

27 Jun 2024

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

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A fine of 12,866 EUR, final since 5 June 2024, was imposed on the motor vehicle dealer by the Arnsberg regional government (Bezirksregierung Arnsberg), as anti-money laundering supervisor for the non-financial sector, for breach of the due diligence obligations of the German Money Laundering Act (Geldwäschegesetz, GwG), and the company was publicly named.

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

Automotive

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

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By final decision of 24 April 2024, Germany's Federal Financial Supervisory Authority (BaFin) imposed a fine of 9.2 million EUR on the neobank because it had systematically filed money laundering suspicious activity reports late in 2022.

Authority / court

Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)

Area of law

Money laundering and terrorist financing · Suspicious activity reports

Legal basis

§ 56 Abs. 1 Nr. 69, Abs. 3 GwG (verspätete Verdachtsmeldungen, § 43 Abs. 1 GwG); Bekanntmachung nach § 57 GwG

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Published

21 May 2024

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

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BaFin imposed a fine of 510,000 EUR on the engine manufacturer because it allegedly had not disclosed inside information without delay. Following an objection by the company, the Local Court of Frankfurt am Main (Amtsgericht) discontinued the proceedings on 21 January 2025 pursuant to Section 47 (2) OWiG (German Administrative Offences Act).

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

overturned

Sector

Manufacturing and mechanical engineering

Published

20 Mar 2024

Amount in EUR; no ECB reference rate is available for this currency.

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

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A vegetable-growing business did not pay harvest workers the collectively agreed minimum wage; the shortfall was just under 300,000 EUR. The investigation was based on interviews conducted with interpreters and the analysis of working time and harvest volume data. Fines of around 200,000 EUR were imposed, and around 300,000 EUR in proceeds of the offence were confiscated in addition (date = publication).

Authority / court

Hauptzollamt Karlsruhe (Finanzkontrolle Schwarzarbeit)

Area of law

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

Legal basis

Mindestlohn- bzw. Tarifrecht (tariflich bestimmter Mindestlohn); Einziehung des Tatertrags

Action

Fine

Status of proceedings

unknown

Sector

Food and agriculture

Published

30 Jan 2024

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

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HHLA had not announced from when and at which internet address the 2021 annual financial report and the 2022 half-yearly financial report were publicly available. The fine has been final since 14 February 2024.

Authority / court

Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)

Area of law

Capital markets and financial supervision · Disclosure and reporting obligations

Legal basis

§ 114 Abs. 1 Satz 2 i. V. m. § 117 Nr. 1 und § 115 Abs. 1 Satz 2 i. V. m. § 117 Nr. 2 WpHG

Action

Fine

Status of proceedings

final

Sector

Transport, logistics and shipping

Published

2 Feb 2024

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

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13 construction companies colluded on industrial construction contracts of Hüttenwerke Krupp Mannesmann (2011–2016), ThyssenKrupp Steel Europe (2007–2017) and Deutsche Edelstahlwerke (2014–2016) and sent each other their calculations so that the others could submit higher sham bids. The Bundeskartellamt imposed fines and liability amounts totalling around 4.8 million EUR on the companies, the former parent company AKM (the first liability amounts under the 2017 amendment to the GWB, the German Act against Restraints of Competition) and twelve responsible individuals; the leniency applicant Hermann Kassens escaped a fine.

Authority / court

Bundeskartellamt

Area of law

Competition law · Cartels and collusion

Legal basis

§ 1 GWB

Action

Fine

Status of proceedings

final

Sector

Construction and real estate

Mitigating circumstances

Settlement by almost all companies; leniency applicant Hermann Kassens Bauunternehmung (proceedings discontinued)

Liability of senior managers

Fines or liability amounts imposed on twelve responsible individuals

Published

14 Dec 2023

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

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The intralogistics and forklift truck group had not disclosed inside information. BaFin imposed a fine of 280,000 EUR, which has been final since January 2024.

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

Manufacturing and mechanical engineering

Published

21 Dec 2023

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

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