Who was sanctioned, and for what?

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.

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

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

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.

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

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

Authority / court

Kommunikationsbehörde Austria (KommAustria)

Area of law

Consumer protection and online retail · Misleading advertising and pricing

Legal basis

§ 16 Abs. 5 Z 4 ORF-G

Action

Order

Status of proceedings

final

Sector

Media and online platforms

Published

29 Jul 2026

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

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.

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

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.

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

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).

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

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

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

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

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

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

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

Authority / court

Verwaltungsgerichtshof (Ausgangsbescheid: Datenschutzbehörde)

Area of law

Data protection · Marketing and consent

Legal basis

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

Action

Fine

Status of proceedings

reduced

Sector

Other

Culpability

negligent

Mitigating circumstances

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

Published

16 Jul 2026

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

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

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

Authority / court

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

Area of law

Data protection · Data subject rights and transparency

Legal basis

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

Action

Order

Status of proceedings

final

Sector

Financial services and insurance

Published

20 Aug 2026

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

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

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.

Authority / court

Eidgenössische Finanzmarktaufsicht (FINMA)

Area of law

Capital markets and financial supervision · Organisational requirements

Legal basis

Verhaltenspflichten nach dem Finanzdienstleistungsgesetz (FIDLEG): Interessenkonflikte, Information, Eignungsprüfung; Auskunftspflicht gegenüber der FINMA

Action

Order

Status of proceedings

unknown

Sector

Financial services and insurance

Liability of senior managers

Measures against individuals are not set out here.

Published

3 Jun 2026

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

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

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.

Authority / court

Eidgenössische Finanzmarktaufsicht (FINMA)

Area of law

Capital markets and financial supervision · Organisational requirements

Legal basis

Verhaltensregeln nach dem Finanzdienstleistungsgesetz (FIDLEG): Interessenkonflikte, Eignungs- und Angemessenheitsprüfung

Action

Order

Status of proceedings

final

Sector

Financial services and insurance

Published

29 Jun 2026

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

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.

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

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

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

Authority / court

Eidgenössischer Datenschutz- und Öffentlichkeitsbeauftragter (EDÖB)

Area of law

Data protection · Marketing and consent

Legal basis

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

Action

Order

Status of proceedings

final

Sector

Retail and e-commerce

Published

26 Jun 2026

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

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.

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

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.

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

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

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.

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

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.

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

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

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.

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

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).

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

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.

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

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).

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

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

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

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).

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

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).

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

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.

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

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.

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

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).

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

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.

Authority / court

Wettbewerbskommission (WEKO)

Area of law

Competition law · Abuse of market power

Legal basis

Kartellgesetz (KG): Missbrauch einer marktbeherrschenden Stellung; Rückweisung BGer 2C_113/2017 vom 12.02.2020

Action

Fine

Status of proceedings

unknown

Sector

Other

Mitigating circumstances

The arena operator concluded an amicable settlement with WEKO.

Published

22 Jan 2026

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

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

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.

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

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

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.

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

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.

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

The Kartellgericht (Cartel Court) fined Pfanner Schutzbekleidung GmbH, Protos GmbH and their holding company (now Pronocer Holding GmbH) 400,000 EUR because, from 9 March 2016 to 25 November 2021, they fixed their dealers' resale prices for work and protective clothing in Austria. Compliance was monitored systematically, dealers who deviated were contacted, and in 2019 a circular reminded all dealers of the prices. Reductions were granted for the settlement, cooperation and a newly introduced compliance system.

Authority / court

Oberlandesgericht Wien als Kartellgericht (Antrag der Bundeswettbewerbsbehörde)

Area of law

Competition law · Cartels and collusion

Legal basis

§ 1 Abs. 1 und 4 KartG und Art. 101 AEUV; § 29 Z 1 lit. a und d KartG

Action

Fine

Status of proceedings

final

Sector

Manufacturing and mechanical engineering

Repeat case

no

Mitigating circumstances

Consensual termination of the proceedings, cooperation with the BWB (Federal Competition Authority), introduction of a compliance system.

Published

18 Sep 2026

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

The Bundesnetzagentur (Federal Network Agency) fined a call centre focused on energy marketing 104,400 EUR for unlawful telephone advertising. Callers frequently posed falsely as the local energy provider or as the person's own supplier and tried to disguise the promotional nature of the calls.

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

unknown

Sector

Other

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

The Bundesnetzagentur (Federal Network Agency) imposed fines totalling 130,000 EUR on an energy company for its sales calls: 105,000 EUR for unlawful telephone advertising to consumers and 25,000 EUR for withholding caller numbers on sales calls. Callers frequently concealed their identity, so that people called were often signed up to contracts they had not wanted; the company has appealed.

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

under appeal

Sector

Energy and utilities

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

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

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

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

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

On 30 September 2025 BaFin (German Federal Financial Supervisory Authority) imposed fines of 910,000 EUR on Oldenburgische Landesbank AG. In 2020 and 2021 the bank lacked adequate IT controls to protect its clients' ownership rights where buy and sell orders were placed on the same day, did not in every case transparently show the costs of the individual components of bundled products, and did not ensure that tied agents properly disclosed inducements. The fine is final.

Authority / court

Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)

Area of law

Capital markets and financial supervision · Organisational requirements

Legal basis

§ 130 Abs. 1 OWiG i. V. m. § 84 Abs. 4 S. 1 WpHG i. V. m. § 10 Abs. 4 Nr. 5 WpDVerOV; § 63 Abs. 9 S. 1 WpHG; § 70 Abs. 1 S. 1 Nr. 2 WpHG i. V. m. Art. 50 Abs. 2 Delegierte Verordnung (EU) 2017/565

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Published

13 Oct 2025

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

A financial services company had rejected several customers' credit card applications by automated means without human involvement despite good creditworthiness, and when asked it did not adequately provide the legally required information and access about the decision. The HmbBfDI (Hamburg data protection authority) imposed 492,000 EUR; substantial process improvements and cooperation were given considerable weight in mitigation, and the company accepted the decision.

Authority / court

Hamburgischer Beauftragter für Datenschutz und Informationsfreiheit (HmbBfDI)

Area of law

Data protection · Data subject rights and transparency

Legal basis

DSGVO – Informations- und Auskunftspflichten bei automatisierten Entscheidungen im Einzelfall

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Mitigating circumstances

Substantial improvement of the process for data subject rights in automated decisions; full cooperation with the authority.

Published

30 Sep 2025

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

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

The Kartellgericht (Cartel Court) fined Bauunternehmung Pusiol GmbH, a subsidiary of Steiner Baugesellschaft m.b.H., allegedly 130,000 EUR for taking part in the construction cartel in Lower Austria from July 2002 to August 2016 (price fixing, market sharing and information exchange in civil engineering tenders). The BWB (Federal Competition Authority) set the fine lower because of the company's limited financial capacity, as it reported annual losses in 2023 and 2024; the company gave a full acknowledgement.

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

Construction and real estate

Repeat case

no

Mitigating circumstances

Limited financial capacity (losses in 2023 and 2024); full acknowledgement.

Published

4 Mar 2026

Checked against the official source on 4 Oct 2026 · Direct link

Customer data (including names, e-mail addresses, dates of birth, telephone numbers) could be retrieved via an unprotected development server of the advertising agency. An employee took the first alert from an external party in January 2025 to be spam; only a second alert in February reached management, which closed the gap but only notified the incident on 2 May 2025 after being requested to do so by the Datenschutzbehörde (Austrian Data Protection Authority, DSB). The authority attributed the employee’s conduct to the company.

Authority / court

Datenschutzbehörde (DSB)

Area of law

Information security and cyber · Incident reporting obligations

Legal basis

Art. 33 Abs. 1 iVm Art. 83 Abs. 4 lit. a DSGVO

Action

Fine

Status of proceedings

final

Sector

Media and online platforms

Culpability

negligent

Mitigating circumstances

No previous infringements and cooperation in the proceedings; gap closed immediately after the second alert, employees trained subsequently.

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

Despite price guarantees it had given, an electricity and gas supplier tried at the end of July 2022 to impose unilateral price increases from 1 September 2022, often raising the unit price by several hundred per cent. The Bundesnetzagentur (Federal Network Agency) found that it had breached the information and transparency duties of Section 41(5) of the Energy Industry Act (EnWG), that the increases were therefore invalid and that from March 2023 it had nonetheless billed customers who had objected at the higher prices; it ordered all adjustments to be withdrawn and reversed within six months and threatened a penalty payment of 100,000 EUR. The Oberlandesgericht Düsseldorf (Higher Regional Court of Düsseldorf) upheld the decision on 13 August 2026 (not final).

Authority / court

Bundesnetzagentur (Bescheid bestätigt durch OLG Düsseldorf, 5. Kartellsenat, Beschluss vom 13.08.2026)

Area of law

Consumer protection and online retail

Legal basis

§ 41 Abs. 5 Satz 1 und 3 EnWG; § 40 Abs. 2 Satz 1 Nr. 3 Alt. 2 EnWG; OLG-Az. VI-5 Kart 2/26 [V]

Action

Order

Status of proceedings

under appeal

Sector

Energy and utilities

Published

14 Aug 2026

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

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

Authority / court

Wettbewerbskommission (WEKO)

Area of law

Competition law · Cartels and collusion

Legal basis

Art. 5 Abs. 3 i.V.m. Abs. 1 KG, Art. 49a Abs. 1 KG

Action

Fine

Status of proceedings

unknown

Sector

Construction and real estate

Mitigating circumstances

Amicable settlements; leniency programme (Duckert free of sanctions)

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

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

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

Authority / court

Bundesanwaltschaft

Area of law

Money laundering and terrorist financing · Internal controls

Legal basis

Art. 102 Abs. 2 StGB i. V. m. Art. 305bis Abs. 1 und 2 StGB

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Mitigating circumstances

Time elapsed since the offence, organisational corrective measures after the affair became known; no compensation claim because of the payment of 16 million CHF to Petrobras.

Published

22 Aug 2025

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

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

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

Authority / court

Bundesanwaltschaft

Area of law

Money laundering and terrorist financing · Customer due diligence

Legal basis

Art. 102 Abs. 2 StGB i. V. m. Art. 305bis Abs. 1 und 2 StGB

Action

Fine

Status of proceedings

final

Sector

Financial services and insurance

Mitigating circumstances

Time elapsed since the offence, very good cooperation in the proceedings, compensation of the private claimant (1MDB).

Published

22 Aug 2025

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

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

In 2023, the Austrian data protection authority (Datenschutzbehörde, DSB) had ordered a local news portal (a media GmbH & Co KG, name pseudonymised) by decision to offer, on the first layer of the cookie banner, an equivalent option to close it without consent. Because the company did not implement this from October 2024 until at least March 2025, the DSB imposed 6,200 EUR for failure to comply with an instruction; the penalty decision is final.

Authority / court

Datenschutzbehörde (DSB)

Area of law

Data protection · Cookies and tracking

Legal basis

Art. 58 Abs. 2 lit. d i. V. m. Art. 83 Abs. 6 DSGVO; Art. 7 DSGVO

Action

Fine

Status of proceedings

final

Sector

Media and online platforms

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

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

On Saturday, 17 December 2022, the management board of a listed real estate company (anonymised in the judgment) approved by email a new share buyback programme including its volume, period and price, but only published it after a formal resolution on Monday, 19 December 2022. Austria's Financial Market Authority (FMA) imposed a penalty of 375,000 EUR; the Federal Administrative Court (Bundesverwaltungsgericht, BVwG) upheld the breach of the ad hoc disclosure obligation but reduced the penalty to 300,000 EUR.

Authority / court

Bundesverwaltungsgericht (Beschwerde gegen Straferkenntnis der Finanzmarktaufsicht FMA)

Area of law

Capital markets and financial supervision · Disclosure and reporting obligations

Legal basis

Art. 17 Abs. 1 MAR i. V. m. § 156 Abs. 3 Z 2, Abs. 4 BörseG 2018

Action

Fine

Status of proceedings

reduced

Sector

Construction and real estate

Culpability

negligent

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