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.

DACH Clear all filters
180cases from 3 jurisdictions
€1.12bnTotal of monetary amounts (127 cases with an amount)
€143.3mLargest single case: Trafigura Beheer B.V.
€498,000Median per case with an amount

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When?

per year, by date of decision
Trend
PeriodCasesTotal
202215€55.8m
202334€204.2m
202445€338m
202553€440.5m
202633€83m

180 cases

13 Aug 2026 Apple Inc., Apple GmbHBundeskartellamt: Apple aligns tracking prompts for its own and third-party apps GermanyAbuse of market power Order

The Bundeskartellamt (Federal Cartel Office) declared binding commitments by Apple on its App Tracking Transparency Framework (ATTF), closing its proceedings under Section 19a(2) of the German Competition Act (GWB) and Article 102 TFEU. According to the preliminary assessment, third-party apps had to obtain, for personalised advertising, an additional and more off-putting consent prompt prescribed by Apple, while Apple used a prompt of its own for its own services; in future the prompts will be aligned so that content, wording and design are neutral, and app providers will be able to combine the required prompts more easily.

What organisations can take from it

Platform privacy rules must be equally strict for a company's own and third-party services, otherwise they become a competition problem themselves.

Relevance to training and awareness

Equal treatment of own and third-party services in consent prompts

Authority / court
Bundeskartellamt
Area of law
Competition law · Abuse of market power
Legal basis
§ 19a Abs. 2 GWB, Art. 102 AEUV (Verpflichtungszusagen, Az. B7-54/25)
Action
Order
Status of proceedings
unknown
Sector
Telecoms, IT and software
Employees
10,000 or more
Published
17 Aug 2026

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

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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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5 Aug 2026 GmbH (im Urteil anonymisiert)Illegal dumping of construction waste: company must pay €375,000 forfeiture AustriaWaste and hazardous substances €375,000

The Oberlandesgericht (OLG, Higher Regional Court) Linz added a forfeiture of 375,000 EUR to the conviction of a limited company under the Verbandsverantwortlichkeitsgesetz (VbVG, Austrian Corporate Criminal Liability Act) for intentionally handling and moving waste in a way that endangered the environment; the suspended corporate fine of 30 daily rates of 500 EUR (15,000 EUR) imposed by the Landesgericht (Regional Court) Salzburg remained in place. From May 2021 to May 2024 and again from May 2025 to February 2026, contrary to the AWG 2002 (Waste Management Act) and partly to an official decision, the company had excavated soil, construction waste, asphalt and concrete rubble accepted for payment and deposited on a plot; removal costs were put at around 3.24 million EUR. Only the forfeiture of EUR 375,000 is recorded as the amount; the corporate fine of EUR 15,000 was conditionally suspended.

What organisations can take from it

Anyone accepting and depositing waste without a permit risks not only a corporate fine but also forfeiture of the fees received for it, which can far exceed the fine.

Relevance to training and awareness

Waste law and official conditions for excavated soil and construction waste

Authority / court
Oberlandesgericht Linz (Berufung gegen Urteil des Landesgerichts Salzburg vom 06.03.2026)
Area of law
Environment and sustainability · Waste and hazardous substances
Legal basis
§ 181b Abs. 1 und 2 StGB; §§ 3, 4 Abs. 1 und 3, § 6 Abs. 1, § 14 Abs. 1 VbVG; § 20 Abs. 3 StGB; AWG 2002
Action
Disgorgement of profits
Status of proceedings
final
Sector
Other
Culpability
intentional
Repeat case
no
Mitigating circumstances
No previous convictions of the company; rather low environmental risk. Further circumstances taken into account by the court concern a natural person and are not reported here.
Liability of senior managers
Under the VbVG, the company's liability is linked to the conduct of its managing director.

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

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29 Jul 2026 Österreichischer Rundfunk (ORF)KommAustria finds unlabelled product placement in ORF's ‘Sport aktuell’ AustriaMisleading advertising and pricing Order

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).

What organisations can take from it

Product placements must be identified and labelled by the editorial team – including logo walls in the background.

Relevance to training and awareness

Labelling of advertising and product placement

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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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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24 Jul 2026 Callcenter (anonymisiert)BNetzA: €34,327 fine on call centre, including for incomplete records of consent GermanyMarketing and consent €34,327

The Bundesnetzagentur (Federal Network Agency) imposed fines totalling 34,327 EUR on a call centre that mainly marketed telecoms products: 32,000 EUR for unlawful telephone advertising and 2,327 EUR because consents to sales calls had not been fully documented. The campaign continued despite the gaps and requests to stop calling were sometimes ignored; the company has appealed.

What organisations can take from it

Consents to telephone marketing must be fully documented – if the proof is missing, the campaign must not continue.

Relevance to training and awareness

Consent and proof of consent for telephone marketing

Authority / court
Bundesnetzagentur (BNetzA)
Area of law
Data protection · Marketing and consent
Legal basis
UWG – Verbot unerlaubter Telefonwerbung gegenüber Verbraucherinnen und Verbrauchern; § 7a UWG (Dokumentation und Aufbewahrung von Einwilligungen)
Action
Fine
Status of proceedings
under appeal
Sector
Other

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

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

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 on Maxxis and two tyre wholesalers that had pushed for the margin guarantees; at the time of publication the decisions were not final (an objection to the Higher Regional Court of Düsseldorf was possible).

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
Published
21 Jul 2026

Checked against the official source on 28 Sep 2026 · Version 2 · 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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24 Jun 2026 Ö Aktiengesellschaft (in der Entscheidung abgekürzt; Adressverlag und Direktwerbeunternehmen)VwGH sets data protection fine for party affinities definitively at 13 million EUR AustriaMarketing and consent €13m

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).

What organisations can take from it

Calculated characteristics such as political leanings are themselves special categories – companies that derive them for advertising need explicit consent.

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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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

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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

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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

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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

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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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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

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20 Apr 2026 flatexDEGIRO SEBaFin fines flatexDEGIRO €1m for late ad hoc disclosure of special audit findings GermanyDisclosure and reporting obligations €1m

On 20 April 2026 BaFin (German Federal Financial Supervisory Authority) imposed a fine of 1,000,000 EUR on flatexDEGIRO SE. At the end of 2022, the company had not published the results of a special audit under § 44 KWG (German Banking Act) at flatexDEGIRO Bank AG, in which BaFin had identified deficiencies in business organisation, without delay as an ad hoc announcement, but only later as a press release. The fine is final.

What organisations can take from it

Supervisory findings can also be inside information; a press release does not replace an ad hoc announcement.

Relevance to training and awareness

Assessing supervisory audit findings as potential inside information

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 (Verordnung (EU) Nr. 596/2014)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
30 Apr 2026

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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

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10 Mar 2026 Barclays PLCBaFin fines Barclays €1.65m over 26 late voting rights notifications GermanyDisclosure and reporting obligations €1.65m

On 10 March 2026 BaFin (German Federal Financial Supervisory Authority) imposed a fine of 1,650,000 EUR on Barclays PLC. Between June 2022 and March 2023 the company had failed in 26 cases to submit voting rights notifications concerning the same issuer on time; the fine punished a breach of the duty of supervision because adequate organisational measures were lacking. The fine is final.

What organisations can take from it

Anyone holding positions in German issuers needs reliable threshold monitoring, or many missed notifications turn into a high fine.

Relevance to training and awareness

Monitoring voting rights thresholds and notifying on time

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
§ 130 Abs. 1 OWiG i. V. m. § 33 Abs. 1 S. 1, § 34 Abs. 1 S. 1, § 38 Abs. 1 S. 1 und § 39 Abs. 1 WpHG
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Liability of senior managers
The fine punished a breach of the duty of supervision under § 130 OWiG (German Administrative Offences Act): the company had not taken adequate organisational measures to prevent the breaches or make them significantly more difficult.
Published
27 Mar 2026

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

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9 Mar 2026 Werbendes Unternehmen aus dem Sektor Finanz- und Versicherungsprodukte (anonymisiert)BNetzA: €50,000 fine on financial products seller posing as an advice centre on the phone GermanyMarketing and consent €50,000

The Bundesnetzagentur (Federal Network Agency) fined a company marketing financial and insurance products 50,000 EUR for unlawful telephone advertising. The calls were particularly intrusive, callers falsely claimed to be an independent advice centre and presented sales calls as service calls; the company has appealed.

What organisations can take from it

Anyone marketing by phone must not disguise either their own identity or the promotional purpose of the call.

Relevance to training and awareness

Consent and proof of consent for telephone marketing

Authority / court
Bundesnetzagentur (BNetzA)
Area of law
Data protection · Marketing and consent
Legal basis
UWG – Verbot unerlaubter Telefonwerbung gegenüber Verbraucherinnen und Verbrauchern
Action
Fine
Status of proceedings
under appeal
Sector
Financial services and insurance

Checked against the official source on 2 Oct 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

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

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3 Mar 2026 Killer GmbH & Co KG, Killer GmbHWaste cartel: €278,000 fine on waste firm Killer despite leniency status AustriaCartels and collusion €278,000

The Kartellgericht (Cartel Court) fined Killer GmbH & Co KG and Killer GmbH allegedly 278,000 EUR for taking part in the nationwide waste management cartel from July 2002 to March 2021, mainly in Lower and Upper Austria and occasionally in Tyrol. The participants fixed prices, shared territories and customers and exchanged competitively sensitive information, including in tenders for waste collection. The fine was reduced because of leniency status and the consensual termination of the proceedings.

What organisations can take from it

A leniency application made only after a dawn raid can reduce a fine but will not necessarily waive it; companies should investigate suspicions internally at an early stage.

Relevance to training and awareness

Territorial and customer allocation in regional markets

Authority / court
Oberlandesgericht Wien als Kartellgericht (Antrag der Bundeswettbewerbsbehörde)
Area of law
Competition law · Cartels and collusion
Legal basis
§ 1 Abs. 1 KartG und Art. 101 Abs. 1 AEUV; § 29 Abs. 1 Z 1 lit. a und d KartG
Action
Fine
Status of proceedings
final
Sector
Energy and utilities
Repeat case
no
Mitigating circumstances
Reduction for cooperation under the leniency programme and the consensual termination of the proceedings.
Published
15 Sep 2026

Checked against the official source on 4 Oct 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

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20 Feb 2026 BVwG reduces FMA penalty against private bank over unclarified beneficial owners AustriaCustomer due diligence €356,000

From 2017 to 2020, an Austrian bank specialising in private and investment banking had not adequately examined the ownership and control structure of an offshore holding client despite the lack of evidence on shareholders, trust arrangements and beneficial owners. The Austrian Federal Administrative Court (Bundesverwaltungsgericht, BVwG) confirmed the infringement but reduced the additional penalty imposed by the Financial Market Authority (Finanzmarktaufsicht, FMA) in its penalty decision of 17 December 2024 from 476,000 to 356,000 EUR (total penalty 436,000 EUR less FMA penalties already paid), because the FMA had taken the seriousness of the offence into account twice and the bank had cooperated, admitted its errors and terminated the client relationship; an appeal on points of law has been permitted.

What organisations can take from it

For offshore holdings with trustees, prove the beneficial owner with supporting documents – a self-declaration is not enough.

Relevance to training and awareness

Identifying beneficial owners in holding and trust structures

Authority / court
Bundesverwaltungsgericht (BVwG); Straferkenntnis der Finanzmarktaufsicht (FMA) vom 17.12.2024
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
§ 9 Abs. 1 erster Satz i. V. m. § 6 Abs. 1 Z 2 FM-GwG; § 35 Abs. 1 und 3 i. V. m. § 34 Abs. 1 Z 2 und Abs. 2 FM-GwG; § 22 Abs. 9 FMABG (Zusatzstrafe)
Action
Fine
Status of proceedings
reduced
Sector
Financial services and insurance
Culpability
negligent
Mitigating circumstances
Reduction by the court because the wrongfulness of the offence had been counted twice, cooperation, admission of the facts and of guilt, and termination of the client relationship

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

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18 Feb 2026 Check24 GmbHBundeskartellamt: Check24 drops best-price clauses towards energy suppliers GermanyAbuse of market power Order

The Bundeskartellamt (Federal Cartel Office) declared binding commitments by Check24 GmbH under which the comparison website gives up price parity clauses when brokering electricity and gas contracts: energy suppliers may offer their tariffs more cheaply via other websites and their own sales channels without the contractual relationship, commission or ranking depending on it (no 'dimming'). In its preliminary assessment the authority had concerns under Articles 101 and 102 TFEU and Sections 1, 19 and 20 of the German Competition Act (GWB).

What organisations can take from it

Leading brokerage platforms should avoid best-price clauses; indirect levers such as a worse ranking also count as parity requirements.

Relevance to training and awareness

Best-price and parity clauses in brokerage contracts

Authority / court
Bundeskartellamt
Area of law
Competition law · Abuse of market power
Legal basis
§ 32b Abs. 1 GWB (Verpflichtungszusagen); Bedenken nach Art. 101, 102 AEUV, §§ 1, 19, 20 GWB (Az. B8-40/25)
Action
Order
Status of proceedings
unknown
Sector
Media and online platforms
Published
24 Feb 2026

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

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17 Feb 2026 BVwG upholds 588,000 EUR FMA penalty against major bank over incorrect risk classification AustriaCustomer due diligence €588,000

The Austrian Federal Administrative Court (Bundesverwaltungsgericht, BVwG) dismissed the appeal of a listed major Austrian bank and upheld the fine of 588,000 EUR (plus 58,800 EUR in procedural costs) imposed by the Financial Market Authority (Finanzmarktaufsicht, FMA) in its penalty decision of 19 November 2024. From 2017 to 2020, the bank had not adequately risk-classified three business relationships and had disregarded sector risks such as gambling and precious metals trading as well as cash intensity; an appeal on points of law has been permitted.

What organisations can take from it

Customers from gambling or precious metals trading with a high share of cash belong in a higher risk class – otherwise the enhanced obligations are missing.

Relevance to training and awareness

Risk classification of cash-intensive high-risk sectors

Authority / court
Bundesverwaltungsgericht (BVwG); Straferkenntnis der Finanzmarktaufsicht (FMA) vom 19.11.2024
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
§ 6 Abs. 5 i. V. m. § 34 Abs. 1 Z 2 und § 35 Abs. 1–3 FM-GwG
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance

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

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4 Feb 2026 Amazon.com, Inc., Amazon EU S.à r.l.Bundeskartellamt bans Amazon price controls and orders disgorgement of around 59 million EUR GermanyAbuse of market power Disgorgement of profits

The Bundeskartellamt (Federal Cartel Office) prohibited Amazon from steering third-party sellers' prices on amazon.de through price control mechanisms that deactivate offers deemed too expensive or exclude them from the 'Buy Box'; such mechanisms are now only permitted exceptionally, for instance in cases of price gouging, with transparent rules and notifications. At the same time, for the first time since the 2023 reform, the authority ordered disgorgement of economic benefits: for the period from 7 November 2023 to 31 December 2024 Amazon must pay around 58.8 million EUR (press release: around 59 million EUR; the exact amount is redacted in the public version).

What organisations can take from it

A platform operator that also sells on its platform must not steer sellers' prices through visibility sanctions and risks having the resulting benefits disgorged.

Relevance to training and awareness

Platform operators interfering in sellers' pricing

Authority / court
Bundeskartellamt
Area of law
Competition law · Abuse of market power
Legal basis
§ 19a Abs. 2 S. 1 Nr. 2 GWB, § 19 Abs. 1, Abs. 2 Nr. 1 GWB, Art. 102 AEUV; Vorteilsabschöpfung nach § 34 Abs. 1 GWB (Az. B2-73/20)
Action
Disgorgement of profits
Status of proceedings
unknown
Sector
Retail and e-commerce
Employees
10,000 or more
Culpability
intentional
Published
5 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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19 Jan 2026 D*** GmbH (Digitalmarketing- und Recruitingagentur, anonymisiert)Recruitment agency: 25,500 EUR for secretly recorded calls with applicants AustriaData subject rights and transparency €25,500

The agency conducted telephone pre-screening interviews with applicants on behalf of client companies, recorded them without valid consent, stored them indefinitely and presented itself as the client company in doing so. The Austrian Data Protection Authority (Datenschutzbehörde, DSB) imposed 25,500 EUR (plus 2,550 EUR in costs) for lack of a legal basis and transparency; the company has lodged an appeal against the amount of the fine with the Federal Administrative Court (Bundesverwaltungsgericht).

What organisations can take from it

Call recordings in recruitment need a genuine legal basis and clear information about who is actually responsible.

Relevance to training and awareness

Recording of telephone calls and applicant data

Authority / court
Datenschutzbehörde
Area of law
Data protection · Data subject rights and transparency
Legal basis
DSGVO Art. 5 Abs. 1 lit. a, c und e, Art. 6 Abs. 1, Art. 12, 13
Action
Fine
Status of proceedings
under appeal
Sector
Other
Employees
Under 50
Mitigating circumstances
No relevant previous violations, cooperation in the proceedings; adjustment of the starting amount to the company's small size.

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

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9 Jan 2026 Bulgarian construction subcontractor: 215,000 EUR for paying below the minimum wage GermanyMinimum wage and undeclared work €215,000

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. Around 215,000 EUR was imposed on the company, corresponding to the economic benefit obtained by paying below the minimum wage; the decision issued in September 2025 has been final since the end of 2025 (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
Published
9 Jan 2026

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

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18 Dec 2025 Werbendes Unternehmen aus dem Energiesektor (anonymisiert)BNetzA: €210,000 fine on energy company over contracts foisted on consumers by phone GermanyMarketing and consent €210,000

The Bundesnetzagentur (Federal Network Agency) fined an energy company 210,000 EUR for unlawful telephone advertising. Callers often posed as the consumer's energy supplier, and in many cases contracts were foisted on the people called; the company has appealed.

What organisations can take from it

Anyone marketing by phone needs verifiable prior consent and must not pose as the existing supplier of the people called.

Relevance to training and awareness

Consent and proof of consent for telephone marketing

Authority / court
Bundesnetzagentur (BNetzA)
Area of law
Data protection · Marketing and consent
Legal basis
UWG – Verbot unerlaubter Telefonwerbung gegenüber Verbraucherinnen und Verbrauchern
Action
Fine
Status of proceedings
under appeal
Sector
Energy and utilities

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

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18 Dec 2025 Werbendes Unternehmen aus dem Sektor Photovoltaik (anonymisiert)BNetzA: €100,500 fine on solar panel seller over disguised sales calls GermanyMarketing and consent €100,500

The Bundesnetzagentur (Federal Network Agency) imposed fines totalling 100,500 EUR on a solar photovoltaic company: 66,000 EUR for unlawful telephone advertising and 34,500 EUR for withholding caller numbers on sales calls. Callers concealed who the calls were really for and in some cases falsely presented sales calls as mere advisory calls.

What organisations can take from it

Even a business that merely commissions sales calls can itself be fined – consent of the people called should be checked before a campaign starts.

Relevance to training and awareness

Consent and proof of consent for telephone marketing

Authority / court
Bundesnetzagentur (BNetzA)
Area of law
Data protection · Marketing and consent
Legal basis
UWG – Verbot unerlaubter Telefonwerbung gegenüber Verbraucherinnen und Verbrauchern; Verbot der Rufnummernunterdrückung bei Werbeanrufen
Action
Fine
Status of proceedings
unknown
Sector
Energy and utilities

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

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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).

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
Measures against individuals are not reported here.

Checked against the official source on 28 Sep 2026 · Version 3 · 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.

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10 Dec 2025 Lech-Stahlwerke GmbHDüsseldorf Higher Regional Court: 21 million EUR fine on Lech-Stahlwerke for price fixing GermanyCartels and collusion €21m

The Oberlandesgericht Düsseldorf (Higher Regional Court of Düsseldorf) fined Lech-Stahlwerke GmbH 21 million EUR for unlawful price fixing and the exchange of competitively sensitive information. This followed a negotiated agreement setting a fine range of 20 to 30 million EUR, after which the company limited its objection against the Bundeskartellamt's (Federal Cartel Office) fining decision of 27 January 2021 to the penalty; the proceedings against BGH Edelstahlwerke GmbH continue separately.

What organisations can take from it

An objection to a cartel fine can end years later in a court-imposed fine running into millions; a negotiated agreement brings predictability, not acquittal.

Relevance to training and awareness

Price fixing and exchange of sensitive information

Authority / court
Oberlandesgericht Düsseldorf, 1. Kartellsenat (Urteil nach Einspruch gegen Bußgeldbescheid des Bundeskartellamts)
Area of law
Competition law · Cartels and collusion
Legal basis
Kartellordnungswidrigkeit (Preisabsprachen, Informationsaustausch); Az. V-1 OWi OLG 1/24 (GWB)
Action
Fine
Status of proceedings
unknown
Sector
Steel and metals
Mitigating circumstances
Negotiated agreement with the objection limited to the penalty; the court found an unlawful delay of one year and seven months in the authority's intermediate procedure.
Published
19 Dec 2025

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4 Dec 2025 Eurowings GmbHDüsseldorf Higher Regional Court bans misleading Eurowings CO2 offsetting claims GermanyMisleading environmental and sustainability claims Order

On appeal by the Verbraucherzentrale Bundesverband (Federation of German Consumer Organisations), the Oberlandesgericht Düsseldorf (Düsseldorf Higher Regional Court) prohibited Eurowings from advertising a €9 CO2 offset during online booking in a way that makes customers believe they travel climate-neutrally; it was not mentioned that other climate-damaging emissions are not offset. By contrast, the court did not consider the 'Sustainable Aviation Fuel' advertising misleading; it did not grant leave to appeal on points of law.

What organisations can take from it

Anyone selling CO2 offsets must point out that only part of the climate impact is offset, even if each individual statement is correct.

Relevance to training and awareness

CO2 offsetting and climate neutrality in customer communication

Authority / court
Oberlandesgericht Düsseldorf, 20. Zivilsenat
Area of law
Environment and sustainability · Misleading environmental and sustainability claims
Legal basis
UWG (irreführende Werbung); Az. I-20 U 38/25
Action
Order
Status of proceedings
unknown
Sector
Transport, logistics and shipping
Published
5 Dec 2025

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

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21 Nov 2025 Rethmann SE & Co. KG (Rethmann-Gruppe, u. a. Remondis)Bundeskartellamt: Rethmann Group must notify future acquisitions for three years GermanyMerger control Order

Applying Section 32f(2) of the German Competition Act (GWB) for the first time, the Bundeskartellamt (Federal Cartel Office) required Rethmann SE & Co. KG and its affiliated companies (the Rethmann Group, which includes Remondis) to notify for three years before completion even mergers below the general turnover thresholds, where the target generates more than 1 million EUR in domestic turnover and at least 100,000 EUR in the collection of non-hazardous municipal waste or the processing of hollow glass. The decision builds on the findings of the sector inquiry into municipal waste completed at the end of 2023; it was not yet final when announced.

What organisations can take from it

Market leaders in regionally defined markets must expect that even small acquisitions below the turnover thresholds may become notifiable.

Relevance to training and awareness

Merger control obligations for small acquisitions

Authority / court
Bundeskartellamt
Area of law
Competition law · Merger control
Legal basis
§ 32f Abs. 2 GWB (Az. B5-31/24)
Action
Order
Status of proceedings
unknown
Sector
Energy and utilities
Published
24 Nov 2025

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

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