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

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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

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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

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19 Nov 2025 Pfanner Schutzbekleidung GmbH, Protos GmbH, Pronocer Holding GmbH (vormals Holding-AG der Gruppe)Pfanner: €400,000 fine for resale price maintenance in workwear trade AustriaCartels and collusion €400,000

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.

What organisations can take from it

Circulars urging dealers to keep to prices are direct evidence of resale price maintenance and should be legally reviewed before they are sent.

Relevance to training and awareness

Resale price maintenance towards dealers

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

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18 Nov 2025 Callcenter mit Tätigkeitsschwerpunkt im Energiesektor (anonymisiert)BNetzA: €104,400 fine on call centre that posed as the customer's energy supplier GermanyMarketing and consent €104,400

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.

What organisations can take from it

Call centres need verifiable consent for every number they dial and must honour requests to stop calling immediately.

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
unknown
Sector
Other

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13 Nov 2025 Werbendes Unternehmen aus dem Energiesektor (anonymisiert)BNetzA: €130,000 fine on energy company over sales calls with withheld numbers GermanyMarketing and consent €130,000

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.

What organisations can take from it

Withholding the caller number or disguising one's identity on sales calls risks additional fines on top of the ban on unsolicited calls.

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
under appeal
Sector
Energy and utilities

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

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13 Nov 2025 BSG: company car does not replace the minimum wage – additional contribution claims upheld GermanyMinimum wage and undeclared work Order

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).

What organisations can take from it

Remuneration models involving benefits in kind should be checked for minimum wage compliance before they are introduced – otherwise additional contribution claims going back years may follow.

Relevance to training and awareness

Minimum wage in money only – benefits in kind in payroll

Authority / court
Bundessozialgericht, 12. Senat (Betriebsprüfung: Deutsche Rentenversicherung Bund)
Area of law
Health and safety and employment law · Minimum wage and undeclared work
Legal basis
§ 1 MiLoG; § 28p SGB IV (Betriebsprüfung)
Action
Order
Status of proceedings
final
Published
14 Nov 2025

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

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28 Oct 2025 Landesbank Hessen-Thüringen Girozentrale (Helaba)BaFin: fine against Helaba over inadequate monitoring systems for money laundering prevention GermanyInternal controls €20,000

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.

What organisations can take from it

Transaction monitoring needs documented indicators and a regular independent quality review – the mere existence of software is not enough.

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
§ 56 Abs. 2 Nr. 11b KWG (Betrieb angemessener Datenverarbeitungssysteme zur Geldwäscheprävention)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
10 Dec 2025

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

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13 Oct 2025 J.P. Morgan SEBaFin: 45 million EUR against J.P. Morgan SE over late suspicious activity reports GermanySuspicious activity reports €45m

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.

What organisations can take from it

File suspicious activity reports without delay – systematic backlogs in the reporting process are themselves an infringement, and the fine can then be calculated on the basis of the institution's total turnover.

Relevance to training and awareness

Filing money laundering suspicious activity reports without delay

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
§ 130 Abs. 1 OWiG (Aufsichtspflichtverletzung) i. V. m. Pflichten nach dem GwG (Verdachtsmeldungen); Bekanntmachung nach § 57 Abs. 1 GwG
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Published
6 Nov 2025

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

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9 Oct 2025 BGH: price reduction only permissible with a clearly legible 30-day lowest price GermanyMisleading advertising and pricing Order

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).

What organisations can take from it

In all discount advertising, state the 30-day lowest price as clearly as the discount itself.

Relevance to training and awareness

Price information in discount advertising (30-day lowest price)

Authority / court
Bundesgerichtshof (I. Zivilsenat), Az. I ZR 183/24
Area of law
Consumer protection and online retail · Misleading advertising and pricing
Legal basis
§ 11 Abs. 1 PAngV; § 5a Abs. 1, § 5b Abs. 4 UWG
Action
Order
Status of proceedings
final
Sector
Retail and e-commerce
Published
9 Oct 2025

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

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30 Sep 2025 Oldenburgische Landesbank AGBaFin fines Oldenburgische Landesbank €910,000 over securities business failings GermanyOrganisational requirements €910,000

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.

What organisations can take from it

Programmed controls in securities settlement must be carefully tested before they are introduced, or management is liable for the gap.

Relevance to training and awareness

Protecting client holdings and disclosing costs and inducements transparently

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

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30 Sep 2025 Unternehmen der Finanzwirtschaft (anonymisiert)HmbBfDI: €492,000 over opaque automated rejection of credit card applications GermanyData subject rights and transparency €492,000

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.

What organisations can take from it

Anyone who rejects applications by automated means must be able to show the people affected, on request and in understandable terms, why the decision was taken and what logic it followed.

Relevance to training and awareness

Transparency in automated decision-making

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

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30 Sep 2025 HmbBfDI: 195,000 EUR against retailer over ignored data subject requests GermanyData subject rights and transparency €195,000

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).

What organisations can take from it

Companies that send advertising must have a working process for access and objection requests – even if the mailing is outsourced.

Relevance to training and awareness

Timely handling of access requests

Authority / court
Hamburgischer Beauftragter für Datenschutz und Informationsfreiheit (HmbBfDI)
Area of law
Data protection · Data subject rights and transparency
Legal basis
DSGVO (Betroffenenrechte)
Action
Fine
Status of proceedings
unknown
Sector
Retail and e-commerce
Published
30 Sep 2025

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

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30 Sep 2025 Bauunternehmung Pusiol GmbHConstruction cartel: €130,000 on civil engineering firm Pusiol, losses considered AustriaCartels and collusion €130,000

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.

What organisations can take from it

Collusion from long ago is still punished; a strained financial position can reduce the fine but cannot avert it.

Relevance to training and awareness

Bid rigging in tenders

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

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4 Sep 2025 A*** GmbH (Werbeagentur, im Bescheid pseudonymisiert)Austrian advertising agency: 870 EUR – alert about security gap dismissed as spam AustriaIncident reporting obligations €870

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.

What organisations can take from it

External alerts about security gaps need a clear intake channel – what ends up in spam still counts as known.

Relevance to training and awareness

Recognising and escalating alerts about security gaps

Missing or inadequate training played a role in the decision.

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

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29 Aug 2025 Strom- und Gasversorger mit mindestens 75.000 Kunden (in der amtlichen Mitteilung anonymisiert)Bundesnetzagentur: energy supplier must reverse invalid price increases GermanyConsumer protection and online retail Order

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).

What organisations can take from it

Price guarantees apply even in an energy crisis; unilateral price rises need a sound legal basis and simple, understandable customer information.

Relevance to training and awareness

Transparent customer information on price changes

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Cover bids and territorial agreements in regional road construction

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

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

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22 Aug 2025 Varengold Bank AGBaFin: 3.3 million EUR fine and penalty payment against Varengold Bank GermanySuspicious activity reports €3.8m

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.

What organisations can take from it

Failing to implement a supervisory order risks penalty payments and a comprehensive package of measures in addition to the fine.

Relevance to training and awareness

Suspicious activity reports and handling of high-risk transactions

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
Bußgeld: § 56 Abs. 1 S. 1 Nr. 69, Abs. 3 GwG; Anordnung: § 51 Abs. 2 GwG, § 44 Abs. 1 KWG; Zwangsgeld: § 14 VwVG i. V. m. § 17 FinDAG; Bekanntmachung nach § 57 Abs. 1 GwG
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Repeat case
yes
Published
16 Sep 2025

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Anti-money laundering and PEP clients

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Customer due diligence and adverse media screening

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

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

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

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6 Aug 2025 DSB: fine against news portal that ignored instruction on cookie banner AustriaCookies and tracking €6,200

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.

What organisations can take from it

Implement orders of the supervisory authority on time – ignoring them risks a separate fine in addition to the original infringement.

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

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31 Jul 2025 BGH: no before-and-after images for nose and chin correction with hyaluronic acid GermanyMisleading advertising and pricing Order

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.

What organisations can take from it

Instagram posts are also advertising – the strict limits of the law on advertising for medicinal products and treatments (Heilmittelwerberecht) apply to aesthetic procedures.

Relevance to training and awareness

Social media advertising for healthcare services

Authority / court
Bundesgerichtshof (I. Zivilsenat), Az. I ZR 170/24
Area of law
Consumer protection and online retail · Misleading advertising and pricing
Legal basis
§ 11 Abs. 1 Satz 3 Nr. 1, § 1 Abs. 1 Nr. 2 Buchst. c HWG; UKlaG
Action
Order
Status of proceedings
final
Sector
Healthcare
Published
31 Jul 2025

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

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9 Jul 2025 Share buyback disclosed too late: BVwG reduces FMA penalty against real estate company AustriaDisclosure and reporting obligations €300,000

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.

What organisations can take from it

A final decision by a corporate body triggers the ad hoc disclosure obligation immediately – weekends and outstanding contractual details do not postpone it.

Relevance to training and awareness

Ad hoc disclosure obligation for decisions of corporate bodies, including at weekends

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Buying cooperations in retail: limits of joint negotiating power

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

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

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

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3 Jul 2025 Sutor Bank GmbHSutor Bank: court cuts fine over conflicts of interest in Riester products to €190,000 GermanyOrganisational requirements €190,000

On 3 July 2025 BaFin (German Federal Financial Supervisory Authority) imposed fines of 702,500 EUR on Sutor Bank GmbH: in 2020 and 2021 the bank had not clearly informed clients, in connection with a possible contract change for Riester pension products, of its own economic interest and thus of conflicts of interest; in 2020 it had not pointed out the associated risks; and in 2021/2022 it had inadequately informed clients about how long telephone recordings are kept. Following the objection, the Amtsgericht Frankfurt am Main (Frankfurt Local Court) set a fine of 190,000 EUR by judgment of 18 August 2026; the judgment is final.

What organisations can take from it

A firm that offers clients a contract change in which it has its own economic interest must clearly disclose that conflict of interest.

Relevance to training and awareness

Disclosing conflicts of interest to clients

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin); Amtsgericht Frankfurt am Main (Einspruchsverfahren)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
§ 63 Abs. 2 S. 1 i. V. m. S. 2 WpHG; § 63 Abs. 6 S. 1, Abs. 13 Nr. 4 WpHG i. V. m. Art. 44 Abs. 2 b) Delegierte Verordnung (EU) 2017/565; § 83 Abs. 5, Abs. 10 S. 1 WpHG i. V. m. Art. 76 Abs. 8 Delegierte Verordnung (EU) 2017/565
Action
Fine
Status of proceedings
reduced
Sector
Financial services and insurance
Published
19 Aug 2025

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

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20 Jun 2025 Saxony: 7,000 EUR fine against art dealer over due diligence obligations and risk management GermanyInternal controls €7,000

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

What organisations can take from it

Art dealers need a written risk analysis and must identify buyers for transactions of 10,000 EUR or more.

Relevance to training and awareness

AML obligations in the art trade

Authority / court
Landesdirektion Sachsen (Geldwäscheaufsicht Nichtfinanzsektor)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Geldwäschegesetz (Sorgfaltspflichten, Risikomanagement); Bekanntmachung nach § 57 GwG
Action
Fine
Status of proceedings
final
Sector
Retail and e-commerce

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

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

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

What organisations can take from it

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

Relevance to training and awareness

High-risk clients and transaction monitoring

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

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

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

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5 Jun 2025 MAGEBA Gesellschaft m.b.H.; Maurer SE, Maurer Söhne Ges. mbH (nur Feststellung)Bridge component suppliers: €400,000 fine on MAGEBA, leniency applicant Maurer not fined AustriaCartels and collusion €400,000

The Kartellgericht (Cartel Court) fined MAGEBA Gesellschaft m.b.H. 400,000 EUR because, from November 2017 to December 2018, it shared customers for road expansion joints and bridge bearings in Austria with a competitor and exchanged information on pricing behaviour. Against Maurer SE and Maurer Söhne Ges. mbH the court merely declared the infringement because of their leniency status. A compliance system introduced in the course of cooperation was taken into account in mitigation, and intent in a hardcore restriction as an aggravating factor.

What organisations can take from it

The first to report a cartel can escape a fine entirely, while those who wait pay; this argues for internal reporting channels and quick decisions on a leniency application.

Relevance to training and awareness

Customer allocation and the leniency programme

Authority / court
Oberlandesgericht Wien als Kartellgericht (Antrag der Bundeswettbewerbsbehörde)
Area of law
Competition law · Cartels and collusion
Legal basis
§ 1 Abs. 1 KartG; § 29 Abs. 1 Z 1 lit. a KartG; § 28 Abs. 1 und 1a Z 1 KartG (Feststellung gegenüber Kronzeugin)
Action
Fine
Status of proceedings
final
Sector
Construction and real estate
Culpability
intentional
Repeat case
no
Mitigating circumstances
Only five projects over about 13 months, no enrichment established, low-level information exchange, the group's economic difficulties, compliance system introduced in the course of cooperation.
Published
18 Nov 2025

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3 Jun 2025 Vodafone GmbHBfDI: 45 million EUR against Vodafone over fraud in partner agencies and authentication gaps GermanyData processors €45m

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

What organisations can take from it

Companies that outsource sales to partner agencies must audit how those agencies handle customer data and make misuse technically harder.

Relevance to training and awareness

Insider threats and oversight of sales partners

Authority / court
Bundesbeauftragte für den Datenschutz und die Informationsfreiheit (BfDI)
Area of law
Data protection · Data processors
Legal basis
Art. 28 Abs. 1 S. 1, Art. 32 Abs. 1 DSGVO
Action
Fine
Status of proceedings
final
Sector
Telecoms, IT and software
Mitigating circumstances
Full cooperation including self-incrimination, modernisation of systems, separation from fraudulent partners; fines accepted and paid, plus donations amounting to millions.
Published
3 Jun 2025

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

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

What organisations can take from it

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

Relevance to training and awareness

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

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

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14 May 2025 SAP SESAP: failure to publish notice on the 2022 annual financial report GermanyDisclosure and reporting obligations €1.75m

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

What organisations can take from it

Even seemingly formal disclosure steps such as the notice announcement need a fixed place in the financial calendar – the range of fines extends up to five per cent of total turnover.

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
§ 114 Abs. 1 Satz 2 WpHG
Action
Fine
Status of proceedings
final
Sector
Telecoms, IT and software
Published
27 May 2025

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13 May 2025 AS Asphaltstraßensanierung, BITUNOVA, Mainka u. a. (Straßenerhaltungskartell, 7 Unternehmen)Bundeskartellamt: 10.5 million EUR against seven road repair companies GermanyCartels and collusion €10.5m

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

What organisations can take from it

Cover bids are not only subject to fines but, for the employees involved, a criminal offence of bid rigging.

Relevance to training and awareness

Cover bids and territorial agreements in tenders

Authority / court
Bundeskartellamt
Area of law
Competition law · Cartels and collusion
Legal basis
§ 1 GWB
Action
Fine
Status of proceedings
final
Sector
Construction and real estate
Mitigating circumstances
Leniency programme (BITUNOVA), settlement
Liability of senior managers
Measures against individuals are not reported here.
Published
13 May 2025

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7 May 2025 Sennheiser electronic SE & Co. KG, Sonova Consumer Hearing Sales Germany GmbHBundeskartellamt: fines against Sennheiser and Sonova over resale price maintenance GermanyCartels and collusion Fine

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

What organisations can take from it

Price monitoring software is no licence: anyone who responds to deviations by putting pressure on dealers is engaging in prohibited resale price maintenance.

Relevance to training and awareness

Price discussions with dealers and price monitoring

Missing or inadequate training played a role in the decision.

Authority / court
Bundeskartellamt
Area of law
Competition law · Cartels and collusion
Legal basis
§ 1 GWB (vertikale Preisbindung)
Action
Fine
Status of proceedings
final
Sector
Retail and e-commerce
Mitigating circumstances
Extensive cooperation and settlement
Published
7 May 2025

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11 Apr 2025 OGH: gyms may not impose fee increases by way of deemed consent AustriaInformation duties in online retail Order

Two gym operators announced a fee increase of 6 EUR a month and treated silence or the failure to exercise a special right of termination as consent. In an action brought by the Austrian Federal Chamber of Labour (Bundesarbeitskammer), the OGH upheld the prohibition of such increases without express agreement and the publication of the judgment; it dismissed claims for repayment and information.

What organisations can take from it

Price increases in ongoing consumer contracts require genuine consent – silence is not enough.

Authority / court
Oberster Gerichtshof (OGH), GZ 4 Ob 51/25s
Area of law
Consumer protection and online retail · Information duties in online retail
Legal basis
§ 6 Abs. 1 Z 2, § 28a KSchG; §§ 1a, 14 UWG
Action
Order
Status of proceedings
final
Sector
Other

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

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

What organisations can take from it

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

Relevance to training and awareness

Cartel risks for intermediate products and active ingredients; leniency programme

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

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

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9 Apr 2025 Alphabet Inc. (Google)Bundeskartellamt: Google commitments on Automotive Services and Google Maps Platform GermanyAbuse of market power Order

In two decisions under Section 19a of the German Competition Act (GWB), the Bundeskartellamt (Federal Cartel Office) declared commitments by Google binding: the services in Google Automotive Services (Maps, Play, Assistant) will in future also be licensed to car manufacturers individually, incentive clauses such as advertising revenue sharing and default settings will be dropped, and interoperability with other providers will be ensured. For the Google Maps Platform, contractual restrictions on combining it with other providers' map services are lifted; the commitments on Automotive Services apply to cars registered in Germany and, owing to uniform EU registration rules, to the European market, while those on the Maps Platform apply at least to licensees with a billing address in the EEA.

What organisations can take from it

Tying and exclusivity incentives in platform services are under scrutiny under Section 19a GWB; individually licensable, interoperable offerings reduce the risk.

Authority / court
Bundeskartellamt
Area of law
Competition law · Abuse of market power
Legal basis
§ 19a GWB (für bindend erklärte Verpflichtungszusagen; Az. B7-25/22)
Action
Order
Status of proceedings
unknown
Sector
Telecoms, IT and software
Employees
10,000 or more
Published
9 Apr 2025

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8 Apr 2025 Securitas Sicherheitsdienstleistungen GmbH, Securitas ABSecuritas: €540,000 fine for collusion in tenders for security services AustriaCartels and collusion €540,000

The Kartellgericht (Cartel Court) imposed a fine of 540,000 EUR, jointly and severally, on Securitas Sicherheitsdienstleistungen GmbH and Securitas AB. From August 2019 to December 2022, an employee coordinated prices and strategic information with a competitor in three private tenders for manned security services. The Bundeswettbewerbsbehörde (BWB, Federal Competition Authority) granted a reduction for the consensual termination of the proceedings.

What organisations can take from it

Even a few coordinated bids in private tenders are enough for a fine; sales teams need clear rules on contacts with competitors.

Relevance to training and awareness

Information exchange with competitors in tenders

Authority / court
Oberlandesgericht Wien als Kartellgericht (Antrag der Bundeswettbewerbsbehörde)
Area of law
Competition law · Cartels and collusion
Legal basis
§ 1 Abs. 1 KartG; § 29 Z 1 lit. a KartG
Action
Fine
Status of proceedings
final
Sector
Defence and security
Employees
1,000 to 9,999
Culpability
intentional
Repeat case
no
Mitigating circumstances
Reduction for the consensual termination of the proceedings.
Published
12 Feb 2026

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25 Mar 2025 Adidas (Sportartikelhersteller)Nuremberg-Fürth Regional Court: Adidas may not claim 'climate neutral by 2050' without explanation GermanyMisleading environmental and sustainability claims Other

On an action by a consumer association, the Landgericht Nürnberg-Fürth (Nuremberg-Fürth Regional Court) ordered Adidas to cease the former statement 'By 2050 we will be climate neutral' on its corporate website and to reimburse warning costs. The statement created the impression that the goal would be reached solely through the company's own emission reductions, although green electricity certificates were also to be used; a reference only in the linked annual report was not sufficient. According to the court's press release of 26 March 2025, the judgment was not final; whether an appeal was lodged is not known here.

What organisations can take from it

Climate targets on a corporate website also count as advertising and must disclose there what role offsetting plays.

Relevance to training and awareness

Climate targets on the corporate website as advertising

Authority / court
Landgericht Nürnberg-Fürth
Area of law
Environment and sustainability · Misleading environmental and sustainability claims
Legal basis
UWG (irreführende Werbung); Az. 3 HK O 6524/24
Action
Other
Status of proceedings
unknown
Sector
Retail and e-commerce
Employees
10,000 or more
Published
26 Mar 2025

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19 Mar 2025 Sennheiser electronic SE & Co KG, Sonova AGSennheiser and Sonova: €634,000 for resale price maintenance on consumer audio products AustriaCartels and collusion €634,000

The Kartellgericht (Cartel Court) imposed fines totalling 634,000 EUR for vertical resale price maintenance on Sennheiser-brand consumer electronics audio products (headphones): 534,000 EUR on Sennheiser electronic SE & Co KG for May 2015 to February 2022 and 100,000 EUR on Sonova AG for March to September 2022. Retailers were given end-customer prices whose observance was monitored; both companies cooperated and did not contest the facts.

What organisations can take from it

Non-binding recommended prices become prohibited resale price maintenance as soon as manufacturers monitor retail prices and object to deviations.

Relevance to training and awareness

Resale price maintenance in online retail

Authority / court
Oberlandesgericht Wien als Kartellgericht (Antrag der Bundeswettbewerbsbehörde)
Area of law
Competition law · Cartels and collusion
Legal basis
Art. 101 Abs. 1 AEUV und § 1 Abs. 1 KartG; § 29 Z 1 lit. a und d KartG
Action
Fine
Status of proceedings
final
Sector
Manufacturing and mechanical engineering
Culpability
intentional
Repeat case
no
Mitigating circumstances
Full cooperation in clarifying the facts; all essential facts left undisputed (acknowledgement).
Published
16 Dec 2025

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17 Mar 2025 Gaslieferant für Haushaltskunden (in der amtlichen Mitteilung anonymisiert)Bundesnetzagentur: conditions for gas supplier after cutting off 350,000 households GermanyConsumer protection and online retail Order

A gas supplier had stopped supplying around 350,000 household customers without notice in December 2021 and terminated the contracts retroactively. When it sought to resume business in 2023, the Bundesnetzagentur (Federal Network Agency) made this subject to conditions because of the management's continuing unreliability: only gradual customer growth until spring 2028, submission of audited annual accounts for 2023 to 2026 and notification of changes to procurement, tariffs and terms until the end of 2027, with penalty payments of up to 100,000 EUR for breaches. The Oberlandesgericht Düsseldorf (Higher Regional Court of Düsseldorf) dismissed the appeal on 23 July 2026; a further appeal on points of law has been allowed.

What organisations can take from it

A supplier that abruptly cuts off household customers must expect years of conditions, as the reliability of its management remains under scrutiny.

Relevance to training and awareness

Supplier obligations towards household customers in energy crises

Authority / court
Bundesnetzagentur (Bescheid bestätigt durch OLG Düsseldorf, 5. Kartellsenat, Beschluss vom 23.07.2026)
Area of law
Consumer protection and online retail
Legal basis
EnWG – Teiluntersagung der Tätigkeit als Energielieferant wegen Unzuverlässigkeit der Geschäftsleitung (Auflagen mit Zwangsgeldandrohung); OLG-Az. VI-5 Kart 1/26 [V]
Action
Order
Status of proceedings
under appeal
Sector
Energy and utilities
Liability of senior managers
The decisive factor was the unreliability of management; according to the court's findings it showed no insight and settled customers' losses only inadequately.
Published
23 Jul 2026

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6 Mar 2025 Talanx AGBaFin fines Talanx €1.095m for late notice on its half-yearly report GermanyDisclosure and reporting obligations €1.1m

On 6 March 2025 BaFin (German Federal Financial Supervisory Authority) imposed a fine of 1,095,000 EUR on Talanx AG. The company had not announced on time from when and at which web address its half-yearly financial report for the 2022 financial year was publicly available in addition to the company register. The fine is final.

What organisations can take from it

Even a seemingly formal availability notice carries fines; financial reporting deadlines belong in the compliance calendar.

Relevance to training and awareness

Meeting deadlines for financial report availability notices

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
§ 115 Abs. 1 S. 2 WpHG
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
25 Mar 2025

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5 Mar 2025 OTTO FUCHS Beteiligungen KGDüsseldorf Higher Regional Court: 30 million EUR on OTTO FUCHS for information exchange among forges GermanyCartels and collusion €30m

The Oberlandesgericht Düsseldorf (Higher Regional Court of Düsseldorf) fined OTTO FUCHS Beteiligungen KG 30 million EUR because two of its authorised officers had, twice a year from October 2010 to November 2015, exchanged information on cost and price components with other aluminium forges in the 'Aluminium Forging Group', for example on customers' discount demands and increased storage costs. The amount covers only the fine imposed on the company.

What organisations can take from it

Regular industry meetings on costs and discounts are risky even without price fixing, and management is personally liable if supervision is inadequate.

Relevance to training and awareness

Information exchange in industry groups and management's duty of supervision

Authority / court
Oberlandesgericht Düsseldorf, 6. Kartellsenat (Kartellbußgeldverfahren)
Area of law
Competition law · Cartels and collusion
Legal basis
Kartellordnungswidrigkeit (Informationsaustausch) und Verletzung der Aufsichtspflicht; Az. V-6 Kart 2/21 OWi
Action
Fine
Status of proceedings
unknown
Sector
Steel and metals
Mitigating circumstances
The exchange was often vague and concerned price components with a small share of costs, so the potential for profit and damage was low; negotiating pressure between aluminium suppliers and the automotive industry. Turnover related to the offence of more than 1 billion EUR and group turnover of around 3.4 billion EUR a year counted against the company.
Published
5 Mar 2025

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

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

What organisations can take from it

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

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

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

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4 Feb 2025 Deutsche Bank AGBaFin fines Deutsche Bank €23.05m for organisational and recording failings GermanyOrganisational requirements €23.1m

On 4 February 2025 BaFin (German Federal Financial Supervisory Authority) imposed fines totalling 23,050,000 EUR on Deutsche Bank AG: 14.8 million EUR because, following allegations about the sale of currency derivatives in Spain, the bank took too long to investigate and remedy the shortcomings; 4.6 million EUR because its Postbank branch at times did not record telephone conversations relating to client orders; and 3.65 million EUR because Postbank failed to provide account-switching assistance in 53 cases. The fine is final.

What organisations can take from it

Compliance allegations abroad must be investigated and remedied swiftly; slow remediation is itself an organisational breach.

Relevance to training and awareness

Complying with recording duties in investment services and account-switching assistance

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
§ 80 Abs. 1 S. 2 Nr. 1 WpHG; § 130 Abs. 1 OWiG i. V. m. § 83 Abs. 3 S. 1 WpHG; §§ 22, 23 Abs. 1 ZKG
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Liability of senior managers
For the telephone-recording complex, a breach of the duty of supervision (§ 130 OWiG, German Administrative Offences Act) was sanctioned: after the pandemic exemptions expired, monitoring and organisational measures were lacking at times.
Published
4 Mar 2025

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3 Feb 2025 Customs investigators: machinery manufacturer allegedly declared Indian steel as British GermanyCustoms Incident

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

What organisations can take from it

For steel, the actual origin determines the customs burden – check supplier declarations from intermediaries for plausibility.

Relevance to training and awareness

Preferential and origin rules when buying steel via intermediaries

Authority / court
Zollfahndungsamt Stuttgart im Auftrag der Europäischen Staatsanwaltschaft (EPPO)
Area of law
Sanctions and export control · Customs
Legal basis
Verdacht der Steuerhinterziehung (Einfuhrabgaben nach EU-Zollrecht, falsche Ursprungsangaben)
Action
Incident without known action
Status of proceedings
unknown
Sector
Steel and metals
Published
3 Feb 2025

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

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

What organisations can take from it

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

Relevance to training and awareness

Payments via intermediaries to employees of state-owned oil companies

Authority / court
Bundesstrafgericht (Strafkammer); Anklage durch die Bundesanwaltschaft
Area of law
Bribery and corruption · Bribery of public officials
Legal basis
Art. 102 StGB i. V. m. Art. 322septies StGB (Bestechung fremder Amtsträger); SK.2023.49
Action
Fine
Status of proceedings
unknown
Sector
Energy and utilities
Employees
10,000 or more
Culpability
intentional
Published
31 Jan 2025

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Handling access requests

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

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28 Jan 2025 OGH raises gun-jumping fine against food retailer from 1.5 to 70 million EUR AustriaMerger control €70m

A food retail group anonymised in the decision (R*) had, through its subsidiary, implemented a notifiable concentration without merger control clearance by means of a long-term lease of store space in a shopping centre (1 July 2018 to 20 September 2022). The Cartel Court (Kartellgericht) imposed a fine of 1.5 million EUR; Austria's Supreme Court (Oberster Gerichtshof, OGH) upheld the appeals of the Federal Competition Authority (Bundeswettbewerbsbehörde, BWB) and the Federal Cartel Prosecutor (Bundeskartellanwalt) and set the fine at 70 million EUR, taking into account the group turnover of 92.3 billion EUR and an earlier fine for prohibited implementation.

What organisations can take from it

Taking over stores by way of a lease or tenancy agreement can also be a notifiable concentration – expansion departments must check merger control requirements.

Relevance to training and awareness

Notification requirement for site takeovers through leases or tenancy agreements

Authority / court
Oberster Gerichtshof als Kartellobergericht (Antrag der Bundeswettbewerbsbehörde)
Area of law
Competition law · Merger control
Legal basis
§ 29 Z 1 lit a iVm § 17 Abs 1 KartG 2005
Action
Fine
Status of proceedings
final
Sector
Retail and e-commerce
Repeat case
yes
Sources

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15 Jan 2025 Saxony: fine against estate agent for breach of AML due diligence obligations GermanyCustomer due diligence €800

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

What organisations can take from it

Estate agents must identify both contracting parties in good time – even small offices are subject to active anti-money laundering supervision.

Relevance to training and awareness

Identification of contracting parties in property brokerage

Authority / court
Landesdirektion Sachsen (Geldwäscheaufsicht Nichtfinanzsektor)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Geldwäschegesetz (Sorgfaltspflichten); Bekanntmachung nach § 57 GwG
Action
Fine
Status of proceedings
final
Sector
Construction and real estate

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27 Dec 2024 Callcenter (anonymisiert)BNetzA: €225,000 fine on call centre over sales calls for electricity and gas contracts GermanyMarketing and consent €225,000

The Bundesnetzagentur (Federal Network Agency) fined a call centre marketing electricity and gas supply contracts 225,000 EUR for unlawful telephone advertising. According to the agency, the share of complaints about energy sales calls fell in 2024, partly because of its large-scale proceedings in the energy sector.

What organisations can take from it

Call centres need verifiable consent for every number they dial and must honour requests to stop calling immediately.

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
unknown
Sector
Other

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19 Dec 2024 Worldcoin FoundationBayLDA: reprimand and erasure orders against Worldcoin over iris codes GermanyData subject rights and transparency Order

Following an investigation of the iris-scanning service begun in 2023, the BayLDA (Bavarian data protection authority for the private sector) issued a decision agreed at European level against the Worldcoin Foundation: a reprimand because iris codes had for a time been stored in plain text, and orders to erase certain iris codes and SMPC shares collected without an adequate legal basis, to provide a GDPR-compliant erasure procedure and to obtain explicit consent. The company has challenged the decision in court; a fine is to be decided separately.

What organisations can take from it

Biometric features cannot be reset – processing them requires explicit consent, secure storage and a working erasure procedure.

Relevance to training and awareness

Biometric data: consent, erasure and security

Authority / court
Bayerisches Landesamt für Datenschutzaufsicht (BayLDA)
Area of law
Data protection · Data subject rights and transparency
Legal basis
Art. 58 Abs. 2 lit. b, d, f, g DSGVO i. V. m. Art. 5 Abs. 1 lit. a, Art. 9 Abs. 1, Art. 17 Abs. 1 und Art. 32 DSGVO
Action
Order
Status of proceedings
under appeal
Sector
Telecoms, IT and software
Published
19 Dec 2024

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

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

What organisations can take from it

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

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

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

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29 Nov 2024 Saubermacher Dienstleistungs-Aktiengesellschaft, Trüger Recycling- und Transport-GesmbH, pink robin gmbhWaste cartel: €7.085m fine on Saubermacher, Trüger and pink robin AustriaCartels and collusion €7.09m

The Kartellgericht (Cartel Court) fined Saubermacher Dienstleistungs-Aktiengesellschaft, Trüger Recycling- und Transport-GesmbH and pink robin gmbh 7.085 million EUR for taking part in a nationwide cartel in waste collection (July 2002 to March 2021). The participants fixed prices, shared markets and exchanged information on public and private tenders; the three companies' periods of involvement differed in length. Starting from 15.58 million EUR, the Bundeswettbewerbsbehörde (BWB, Federal Competition Authority) granted a reduction for the consensual termination of the proceedings.

What organisations can take from it

Tacitly leaving each other's home territories alone (home-market principle) is a hardcore restriction and is punished like an express agreement.

Relevance to training and awareness

Market sharing and price fixing between competitors

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 Z 1 lit. a und d KartG
Action
Fine
Status of proceedings
final
Sector
Energy and utilities
Repeat case
no
Mitigating circumstances
Reduction for the consensual termination of the proceedings (starting amount 15.58 million EUR).
Published
8 May 2026

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25 Nov 2024 KT Bank AGBaFin imposes 30 fines totalling €600,000 on KT Bank for AML and banking law breaches GermanyCustomer due diligence €600,000

BaFin (German Federal Financial Supervisory Authority) imposed 30 fines of 20,000 EUR each, 600,000 EUR in total, on KT Bank AG. Among other things, the bank had not effectively monitored its internal safeguards, had not retained identification records, had not continuously monitored business relationships, had not recorded the names of beneficial owners, had failed to file suspicious activity reports and had granted loans without fully reviewing the financial circumstances under the disclosure requirements. The decision of 25 November 2024 has been final since 20 December 2024.

What organisations can take from it

Many gaps in the customer process, from identification to suspicious activity reporting, are fined individually and add up.

Relevance to training and awareness

Identifying beneficial owners and continuously monitoring business relationships

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
§ 56 Abs. 1 Nr. 3, 7, 20, 21, 30, 33 und 69 GwG; § 56 Abs. 2 Nr. 5 KWG
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
23 Jan 2025

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18 Nov 2024 Meta Platforms Ireland Ltd.BGH: loss of control after Facebook scraping can be compensable damage (VI ZR 10/24) GermanyData breaches and data security Other

Unknown persons had linked data on a very large number of Facebook users to telephone numbers via the contact import function, harvested it and later made it public. Germany's Federal Court of Justice (Bundesgerichtshof, BGH) ruled that the mere loss of control over one's own data can constitute non-material damage under Art. 82 GDPR, without proof of specific misuse; it considered compensation in the order of 100 EUR legally unobjectionable in the circumstances of the case. The case was referred back to the Higher Regional Court of Cologne (OLG Köln), among other things to examine the default searchability setting in the light of data minimisation.

What organisations can take from it

Data breaches can trigger compensation claims even without proven misuse; with millions of data subjects, this adds up to a mass risk.

Authority / court
Bundesgerichtshof (VI. Zivilsenat)
Area of law
Data protection · Data breaches and data security
Legal basis
Art. 82 Abs. 1 DSGVO
Action
Other
Status of proceedings
unknown
Sector
Media and online platforms
Employees
10,000 or more
Published
18 Nov 2024

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12 Nov 2024 Hamburger Dienstleister aus dem Forderungsmanagement (anonymisiert)HmbBfDI: €900,000 fine on debt collector for failing to delete debtor data GermanyData protection €900,000

During a sector-wide audit of major debt collection firms, the HmbBfDI (Hamburg data protection authority) found on site that a Hamburg service provider had kept a six-figure number of records on debtors without a legal basis until mid-November 2023, in some cases five years beyond the statutory retention period. The company admitted the infringement and accepted the 900,000 EUR fine; its cooperation in dealing with the matter was taken into account.

What organisations can take from it

A deletion policy with fixed retention periods must be in place before data is collected and must actually be applied in the database.

Relevance to training and awareness

Deletion policy and retention periods

Authority / court
Hamburgischer Beauftragter für Datenschutz und Informationsfreiheit (HmbBfDI)
Area of law
Data protection
Legal basis
Art. 5 Abs. 1 lit. a, Art. 6 Abs. 1 DSGVO
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Infringement admitted, fine accepted, professional cooperation in remedying the matter.
Published
12 Nov 2024

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6 Nov 2024 Strabag AG (Köln); Kemna Bau Andreae GmbH & Co. KG als Kronzeuge ohne BußgeldBundeskartellamt: 2.79 million EUR against Strabag over collusion on Cologne's Zoobrücke GermanyCartels and collusion €2.79m

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

What organisations can take from it

A single rigged tender is enough for a fine and criminal proceedings – compensation payments between bidders are a clear red flag.

Relevance to training and awareness

Cover bids and compensation payments in individual tenders

Authority / court
Bundeskartellamt
Area of law
Competition law · Cartels and collusion
Legal basis
§ 1 GWB
Action
Fine
Status of proceedings
final
Sector
Construction and real estate
Employees
10,000 or more
Mitigating circumstances
Settlement
Liability of senior managers
Bid rigging is also a criminal offence for the individuals involved under Section 298 StGB (German Criminal Code); their prosecution is a matter for the public prosecutor.
Published
6 Nov 2024

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16 Oct 2024 OGH: 100,000 EUR gun-jumping fine for premature start of a mask production joint venture AustriaMerger control €100,000

A textile company started operations with a joint venture (H* GmbH) for the production of protective masks on 24 April 2020, before the notifiable concentration had been cleared; the infringement lasted until 25 May 2020. The Cartel Court imposed a fine of 5,000 EUR; the OGH increased the fine to 100,000 EUR.

What organisations can take from it

The standstill obligation applies even in emergencies such as the pandemic – a joint venture may only start operating after clearance.

Relevance to training and awareness

Standstill obligation before clearance (gun-jumping), including in crisis situations

Authority / court
Oberster Gerichtshof als Kartellobergericht (Antrag der Bundeswettbewerbsbehörde)
Area of law
Competition law · Merger control
Legal basis
§ 29 Z 1 lit a iVm § 17 Abs 1 KartG 2005
Action
Fine
Status of proceedings
final
Sector
Other
Culpability
intentional
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16 Oct 2024 OGH: 65,000 EUR fine against joinery over cover bids and market sharing AustriaCartels and collusion €65,000

From February 2011 to October 2016, a construction and furniture joinery anonymised in the decision (together with its general partner GmbH) participated in agreements on successful bidders, cover bids, market sharing and information exchange in tenders in Lower Austria and Vienna. The Cartel Court imposed a fine of 55,000 EUR only for 26 infringements up to June 2016; the OGH upheld the appeals of the BWB and the Federal Cartel Prosecutor and set a fine of 65,000 EUR on a joint and several basis for the entire period.

What organisations can take from it

Even small craft businesses are penalised for cover bids – "courtesy bids" among colleagues are competition law infringements.

Relevance to training and awareness

Cover bids in tenders for craft trades

Authority / court
Oberster Gerichtshof als Kartellobergericht (Antrag der Bundeswettbewerbsbehörde)
Area of law
Competition law · Cartels and collusion
Legal basis
§ 1 Abs 1 KartG 2005, §§ 28, 29 KartG
Action
Fine
Status of proceedings
final
Sector
Construction and real estate
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16 Oct 2024 DSB: 5,000 EUR against Covid laboratory with managing director as data protection officer AustriaData protection €5,000

A limited company operating a diagnostic laboratory (name pseudonymised), which during the pandemic carried out up to 45,000 PCR analyses a day with around 200 employees, had appointed its managing director as data protection officer at the same time. Because of the resulting conflict of interest, the Austrian data protection authority (Datenschutzbehörde, DSB) imposed 5,000 EUR; the penalty decision is final.

What organisations can take from it

Whoever decides on the purposes and means of processing cannot monitor themselves as data protection officer.

Authority / court
Datenschutzbehörde (DSB)
Area of law
Data protection
Legal basis
Art. 37, Art. 38 Abs. 6 DSGVO
Action
Fine
Status of proceedings
final
Sector
Healthcare
Employees
50 to 249
Liability of senior managers
The managing director was also appointed as data protection officer – an impermissible conflict of interest.

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23 Sep 2024 a dominant Austrian postal operatorAustria: EUR 9.2m fine on a postal operator for discriminatory bulk mail discounts AustriaAbuse of market poweranonymised €9.2m

The Kartellgericht (Cartel Court) fined an Austrian postal operator 9.2 million EUR for abusing its dominant position in addressed bulk mail from 2017 to early 2022: consolidators received worse discount scales, discounts or annual bonuses than other large customers for the same annual volume, and the discounts agreed with large customers were subject to a confidentiality obligation. The fine followed an already final cease-and-desist order obtained by a consolidator; the company acknowledged the infringement in a settlement.

What organisations can take from it

Dominant companies must design discount schemes so that comparable customers, including consolidators, are not disadvantaged, and must not shield terms behind confidentiality clauses.

Relevance to training and awareness

Abuse of market power through discount schemes

Authority / court
Oberlandesgericht Wien als Kartellgericht (Antrag der Bundeswettbewerbsbehörde)
Area of law
Competition law · Abuse of market power
Legal basis
§ 5 KartG und Art. 102 AEUV; § 29 Abs. 1 Z 1 lit. a und d KartG
Action
Fine
Status of proceedings
final
Sector
Transport, logistics and shipping
Employees
10,000 or more
Repeat case
no
Mitigating circumstances
Reduction for the consensual termination of the proceedings (settlement); damage already made good.
Published
25 Feb 2025

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

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

What organisations can take from it

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

Relevance to training and awareness

Relative market power and refusal to supply on foreign terms

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

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

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

What organisations can take from it

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

Relevance to training and awareness

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

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

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

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16 Aug 2024 DSB: 1.5 million EUR against retail chain over cameras on self-checkouts, PIN pad and surroundings AustriaVideo surveillanceanonymised €1.5m

In 2022, a retail company (name pseudonymised) used nine cameras in one branch to film, among other things, the self-service checkouts including the keypad of the card payment terminal, as well as public areas, bus stops and neighbouring properties. The Austrian data protection authority (Datenschutzbehörde, DSB) imposed 1.5 million EUR for lack of a legal basis and infringement of data minimisation; the Federal Administrative Court (Bundesverwaltungsgericht, BVwG) confirmed the amount on 25 July 2025, and an appeal on points of law is pending.

What organisations can take from it

Align cameras in retail closely with their protective purpose – PIN entries, public spaces and neighbouring properties must not be in the frame.

Authority / court
Datenschutzbehörde (DSB)
Area of law
Data protection · Video surveillance
Legal basis
Art. 5 Abs. 1 lit. a und c, Art. 6 Abs. 1 DSGVO
Action
Fine
Status of proceedings
under appeal
Sector
Retail and e-commerce

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12 Aug 2024 a German digital bankBaFin: EUR 1.25 million fine on a digital bank over late suspicious activity reports GermanySuspicious activity reportsanonymised €1.25m

BaFin imposed a fine of EUR 1,250,000 on a German digital bank. According to BaFin, between March 2021 and June 2023 the institution systematically filed money laundering suspicious activity reports with the FIU late. According to BaFin, the decision is final.

What organisations can take from it

Suspicious activity reports brook no delay; filing them systematically late over years can lead to a fine in the millions.

Relevance to training and awareness

Filing suspicious activity reports with the FIU on time

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
§ 56 Abs. 1 Nr. 69, Abs. 3 GwG
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
1 Oct 2024

Checked against the official source on 2 Oct 2026 · Company name anonymised since 12 Aug 2026 · Direct link

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5 Aug 2024 a Swiss commodities groupSwiss Attorney General: summary penalty order against commodities group over bribery in Congo SwitzerlandBribery of public officialsanonymised €138.9m

The group failed to take all reasonable organisational precautions to prevent the bribery of foreign public officials by a business partner in connection with the acquisition of minority stakes in two mining companies in the DR Congo in 2011. The Office of the Attorney General of Switzerland (Bundesanwaltschaft, BA) issued a summary penalty order (Strafbefehl) imposing a fine of 2 million CHF and a compensatory claim of 150 million USD (amount converted at the ECB rate of 5 August 2024: 152,357,266 USD in total); further matters from 2007–2017 were discontinued.

What organisations can take from it

Companies are also liable for bribery by business partners if they have not taken adequate due diligence and control measures.

Relevance to training and awareness

Corruption risks posed by business partners in acquisitions of stakes

Authority / court
Bundesanwaltschaft (BA)
Area of law
Bribery and corruption · Bribery of public officials
Legal basis
Art. 102 Abs. 2 StGB (Unternehmensverantwortlichkeit) i. V. m. Bestechung fremder Amtsträger; Strafbefehl
Action
Fine
Status of proceedings
unknown
Sector
Steel and metals
Employees
10,000 or more
Culpability
intentional
Published
5 Aug 2024

Original amount 152,357,266 USD, converted at the ECB reference rate of 5 Aug 2024.

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3 Jul 2024 a French major bankBaFin fines a French major bank €830,000 over cost disclosures and suitability assessments GermanyOrganisational requirementsanonymised €830,000

On 3 July 2024 BaFin (German Federal Financial Supervisory Authority) imposed fines totalling 830,000 EUR on a French major bank. In individual cases in the 2019/2020 financial year, its German branch had not informed clients on time and as required about all costs and associated charges of financial instruments, and had provided investment services without obtaining sufficient information on clients' financial situation in the suitability assessment. The fine is final.

What organisations can take from it

Cost disclosure and suitability assessment are core investor protection duties; even individual failures lead to high fines.

Relevance to training and awareness

Carrying out MiFID II cost disclosures and suitability assessments correctly

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
§ 63 Abs. 7 bis 9 WpHG, Art. 46 Abs. 2 und Art. 50 Abs. 2 Delegierte Verordnung (EU) 2017/565; § 64 Abs. 3 WpHG i. V. m. Art. 54 Abs. 4 Delegierte Verordnung (EU) 2017/565
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Published
25 Jul 2024

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27 Jun 2024 an Austrian industrial goods manufacturer and its owning entityAustria: EUR 3m fine on an industrial goods manufacturer for resale price maintenance and territorial protection AustriaCartels and collusionanonymised €3m

The Kartellgericht (Cartel Court) imposed a joint fine of EUR 3 million on an Austrian industrial goods manufacturer and its owning entity for a long-running infringement in the distribution of its own products in Austria between 2007 and 2021. Resale prices, a territorial split and non-compete obligations were agreed with authorised dealers, together with concerted practices such as cover bids. The companies acknowledged the infringement and received reductions for cooperation and settlement.

What organisations can take from it

Distribution agreements must be checked for resale price maintenance, territorial protection and non-compete clauses before signature; cover bids by dealers at the manufacturer's request are also cartel infringements.

Relevance to training and awareness

Resale price maintenance and territorial protection in distribution agreements

Authority / court
Oberlandesgericht Wien als Kartellgericht (Antrag der Bundeswettbewerbsbehörde)
Area of law
Competition law · Cartels and collusion
Legal basis
§ 1 KartG und Art. 101 AEUV; § 29 Z 1 lit. a und d KartG
Action
Fine
Status of proceedings
final
Sector
Manufacturing and mechanical engineering
Culpability
intentional
Repeat case
no
Mitigating circumstances
Acknowledgement of the infringement; reductions for cooperation and settlement.
Published
10 Jan 2025

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27 Jun 2024 BGH: advertising with ‘climate neutral’ only permissible with explanation in the advertisement itself GermanyMisleading environmental and sustainability claimsanonymised Order

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

What organisations can take from it

Companies advertising with ‘climate neutral’ must explain directly in the advertisement whether emissions are avoided or merely offset.

Relevance to training and awareness

Legally compliant environmental and climate claims in advertising

Authority / court
Bundesgerichtshof (I. Zivilsenat)
Area of law
Environment and sustainability · Misleading environmental and sustainability claims
Legal basis
§ 3 Abs. 1, § 5 Abs. 1, § 5a Abs. 1 und 3, § 8 Abs. 1 Satz 1 UWG
Action
Order
Status of proceedings
final
Sector
Food and agriculture
Published
27 Jun 2024

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20 Jun 2024 a German business that commissioned sales calls for food supplementsBNetzA: €200,000 fine on business that commissioned sales calls for food supplements GermanyMarketing and consentanonymised €200,000

The Bundesnetzagentur (Federal Network Agency) fined a business that had commissioned sales calls for food supplements 200,000 EUR for unlawful telephone advertising. The official list states only the role, the product advertised and the amount.

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
Action
Fine
Status of proceedings
unknown
Sector
Retail and e-commerce

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18 Jun 2024 a Swiss private bankFINMA: Swiss private bank breached anti-money laundering rules for two PEPs SwitzerlandCustomer due diligenceanonymised Order

The Swiss Financial Market Supervisory Authority (FINMA) found that, for two politically exposed persons, the bank insufficiently clarified the origin and purpose of assets – transactions of more than 300 million USD from a Lebanese state institution between 2002 and 2015 – and only reported them to the reporting office in September 2020. It ordered a review of all PEP relationships, a ban on new PEP relationships until the review is completed and the appointment of an audit agent; the decision was not final at the time of publication (date of the announcement used as decision date).

What organisations can take from it

In PEP relationships, document the origin and purpose of large payments; a report made years later is no report.

Relevance to training and awareness

Dealing with politically exposed persons (PEPs)

Authority / court
Eidgenössische Finanzmarktaufsicht (FINMA)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Schweizer Geldwäschereirecht (laut FINMA)
Action
Order
Status of proceedings
unknown
Sector
Financial services and insurance
Published
18 Jun 2024
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10 Jun 2024 a Valais transport and waste disposal company and four other companiesWEKO: sanction against Valais transport and waste disposal firm over bid rigging SwitzerlandCartels and collusionanonymised €98,722

Companies engaged in the collection, transport and disposal of waste in Valais colluded on bids. WEKO imposed a sanction of CHF 95,138 on the transport and waste disposal company (another company: CHF 0), approved amicable settlements and apportioned the procedural costs among four companies.

What organisations can take from it

Municipal waste disposal contracts are a focus of competition authorities – contacts about bids among competitors are off-limits, including among SMEs.

Relevance to training and awareness

Collusion in municipal waste disposal tenders

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
Transport, logistics and shipping
Mitigating circumstances
Amicable settlements; leniency programme (another company free of sanctions)

Original amount 95,138 CHF, converted at the ECB reference rate of 10 Jun 2024.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 10 Jun 2026 · Direct link

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10 Jun 2024 a German network equipment manufacturerBundeskartellamt: almost €16m on network equipment maker for resale price maintenance GermanyCartels and collusionanonymised Fine

The Bundeskartellamt (Federal Cartel Office) fined a German network equipment manufacturer and one responsible individual a total of almost 16 million EUR for resale price maintenance: the manufacturer's staff coordinated increases in consumer prices for its products with six electronics retailers, in some cases demanded target prices, monitored prices with dedicated software and in some cases threatened supply stops or reduced terms. The case began with an anonymous tip-off to the whistleblowing system and further market information; the decisions are final following a settlement, and no fines were imposed on the retailers.

What organisations can take from it

Target price lists and monitoring of retailers' prices by sales staff are evidence of resale price maintenance; sales teams need clear limits on price management.

Relevance to training and awareness

Resale price maintenance by sales teams

Authority / court
Bundeskartellamt
Area of law
Competition law · Cartels and collusion
Action
Fine
Status of proceedings
final
Sector
Telecoms, IT and software
Mitigating circumstances
Expedited settlement.
Published
2 Jul 2024

Checked against the official source on 2 Oct 2026 · Company name anonymised since 10 Jun 2026 · Direct link

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5 Jun 2024 a German car dealerCar dealer: 12,866 EUR fine for breach of AML due diligence obligations GermanyCustomer due diligenceanonymised €12,866

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

What organisations can take from it

Car dealerships must identify and document buyers for cash payments of 10,000 EUR or more – sales staff must know the threshold.

Relevance to training and awareness

Customer identification when selling vehicles for cash

Authority / court
Bezirksregierung Arnsberg (Geldwäscheaufsicht Nichtfinanzsektor)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Geldwäschegesetz (Sorgfaltspflichten); Bekanntmachung nach § 57 GwG
Action
Fine
Status of proceedings
final
Sector
Automotive

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4 Jun 2024 an Austrian general importer of a car brandAustria: EUR 15m fine on a car importer for abusing market power over a dealer AustriaAbuse of market poweranonymised €15m

The Kartellgericht (Cartel Court) fined the Austrian general importer of a car brand 15 million EUR for abusing its dominant position (relative market power) over an authorised dealer from 2017 or 2018 until 22 March 2021. The court objected to bonuses tied to customer satisfaction surveys, deliberately inflated sales targets, low prices charged by group-owned dealers while the dealer was given unfavourable terms, warranty and guarantee work paid below cost, and costs for mystery shopping and audits passed on to the dealer. A final cease-and-desist order obtained by the dealer had preceded the fine.

What organisations can take from it

Manufacturers and importers must check whether authorised dealers depend on them and, if so, scrutinise bonus, target and remuneration schemes particularly carefully for abuse.

Relevance to training and awareness

Fair terms in dealer and workshop agreements

Authority / court
Oberlandesgericht Wien als Kartellgericht (Antrag der Bundeswettbewerbsbehörde)
Area of law
Competition law · Abuse of market power
Legal basis
§ 5 KartG; § 29 Abs. 1 Z 1 lit. a KartG
Action
Fine
Status of proceedings
final
Sector
Automotive
Culpability
intentional
Repeat case
no
Published
20 Jan 2025

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24 May 2024 a German investment firm of an international banking groupBaFin fines an investment firm €12.975m over algorithmic trading controls GermanyOrganisational requirementsanonymised €13m

On 24 May 2024 BaFin (German Federal Financial Supervisory Authority) imposed a fine of 12,975,000 EUR on a German investment firm of an international banking group. In May 2022 the investment firm lacked suitable systems and risk controls with appropriate trading thresholds and limits for its algorithmic trading; a manual input error by a trader at a sister company in London, to which monitoring had been outsourced, went undetected and caused a market disruption. The fine is final.

What organisations can take from it

A firm that outsources the monitoring of its algorithmic trading remains fully responsible for effective trading limits and controls against erroneous orders.

Relevance to training and awareness

Outsourcing does not remove responsibility for trading controls

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
§ 80 Abs. 2 S. 3 Nr. 1 und 2 WpHG
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
20 Jun 2024

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21 May 2024 fourteen Swiss gravel and construction companiesWEKO fines a gravel pit and its shareholders CHF 5.3 million SwitzerlandCartels and collusionanonymised €5.37m

A gravel extraction joint venture, the largest gravel and landfill pit in its region, and its shareholders coordinated through the joint venture's board, granted the shareholders cheaper gravel prices and transport subsidies, undertook not to extract gravel themselves in the joint venture's area and for a time tied the dumping of excavated material to gravel purchases. The Wettbewerbskommission (WEKO, Swiss Competition Commission) imposed sanctions totalling CHF 5,303,750: CHF 3,131,100 on the joint venture, CHF 383,150 on a first shareholder group of three companies, CHF 304,150 on a second group of three companies, CHF 460,750 on a third group of two companies, CHF 242,500 on a gravel works, CHF 387,100 on a fourth group of two companies and CHF 395,000 on a fifth group of two companies, together with conduct requirements concerning the joint venture's board and management. With the exception of individual points, the ruling is under appeal before the Federal Administrative Court (as of December 2025).

What organisations can take from it

Where competitors sit together on the board of a joint venture, clear information barriers are needed, or the board becomes a cartel platform.

Relevance to training and awareness

Joint ventures between competitors: information exchange and collusion on the board

Authority / court
Wettbewerbskommission (WEKO)
Area of law
Competition law · Cartels and collusion
Legal basis
Art. 49a Abs. 1 i.V.m. Art. 5 Abs. 1, 3 und 4 KG; bei KAGA zusätzlich Art. 7 Abs. 1 i.V.m. Abs. 2 KG
Action
Fine
Status of proceedings
under appeal
Sector
Construction and real estate
Mitigating circumstances
Several parties concluded amicable settlements with the WEKO secretariat, which WEKO approved.
Published
27 Aug 2024

Original amount 5,303,750 CHF, converted at the ECB reference rate of 21 May 2024.

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14 May 2024 a German call centreBNetzA: €315,000 fine on call centre over unlawful sales calls for energy contracts GermanyMarketing and consentanonymised €315,000

The Bundesnetzagentur (Federal Network Agency) fined a call centre marketing energy supply contracts 315,000 EUR for unlawful telephone advertising. The official list states only the role, the product advertised and the amount; according to the agency's annual review, each of its major fine proceedings in 2024 followed up several hundred to more than 2,000 complaints.

What organisations can take from it

Call centres need verifiable consent for every number they dial and must honour requests to stop calling immediately.

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
unknown
Sector
Other

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1 May 2024 a Swiss IT service provider and two Swiss federal officesFDPIC: data protection infringements at IT service provider and two federal offices after ransomware attack SwitzerlandData processorsanonymised Other

Following the hacker attack on an IT service provider, the Swiss Federal Data Protection and Information Commissioner (Eidgenössischer Datenschutz- und Öffentlichkeitsbeauftragter, EDÖB) found that personal data of two federal offices had reached the service provider via support processes without the necessary data protection safeguards. The service provider subsequently retained the data in breach of data protection law and partly in breach of contract.

What organisations can take from it

Real data does not belong in service providers' support and test environments – clients must control disclosure and deletion.

Relevance to training and awareness

Passing real data to service providers for support

Authority / court
Eidgenössischer Datenschutz- und Öffentlichkeitsbeauftragter (EDÖB)
Area of law
Data protection · Data processors
Legal basis
Datenschutzgesetz (DSG)
Action
Other
Status of proceedings
unknown
Sector
Telecoms, IT and software
Published
1 May 2024

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24 Apr 2024 a German neobankBaFin: 9.2 million EUR against neobank over systematically late suspicious activity reports GermanySuspicious activity reportsanonymised €9.2m

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

What organisations can take from it

Send suspicious activity reports to the FIU without delay – systematically late reporting risks fines running into millions.

Relevance to training and awareness

Suspicious activity reports without delay

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
§ 56 Abs. 1 Nr. 69, Abs. 3 GwG (verspätete Verdachtsmeldungen, § 43 Abs. 1 GwG); Bekanntmachung nach § 57 GwG
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
21 May 2024

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28 Mar 2024 a Swiss private bankPrivate bank fined CHF 750,000 for organisational failings over money laundering SwitzerlandInternal controlsanonymised €767,971

In the Lava Jato case complex, the Bundesanwaltschaft (BA, Office of the Attorney General of Switzerland) found that between 2011 and 2014 a Swiss private bank did not adequately establish beneficial owners and the background of transactions at its Lugano office, enabling two employees to commit money laundering exceeding USD 20 million. By summary penalty order of 28 March 2024 the bank was fined CHF 750,000; the BA dropped the charge of bribery of foreign public officials. The bank waived its right to object, so the penalty order becomes final.

What organisations can take from it

For accounts with conspicuous structures, beneficial ownership must be checked independently of the relationship manager.

Relevance to training and awareness

Establishing beneficial owners and front-man structures

Authority / court
Bundesanwaltschaft (BA)
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Art. 102 Abs. 2 StGB i.V.m. Art. 305bis Ziff. 2 StGB
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
The bank's cooperation with the Office of the Attorney General was taken into account.
Published
4 Apr 2024

Original amount 750,000 CHF, converted at the ECB reference rate of 28 Mar 2024.

Checked against the official source on 2 Oct 2026 · Company name anonymised since 28 Mar 2026 · Direct link

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25 Mar 2024 a Swiss bankFINMA confiscates 3.9 million CHF in profits from Swiss bank SwitzerlandSuspicious activity reportsanonymised €4.01m

The Swiss Financial Market Supervisory Authority (FINMA) found serious infringements of anti-money laundering rules in PEP relationships: insufficient clarification of the origin of assets, failure to report to the reporting office despite unexplained transaction purposes and a serious breach of the duty to provide information, because a critical internal audit report was not handed over. It confiscated 3.9 million CHF in profits, imposed a capital surcharge of 19 million CHF and a two-year ban on new PEP and high-risk relationships (date of the announcement used as decision date).

What organisations can take from it

Withholding critical audit reports from the supervisory authority considerably aggravates a money laundering case.

Relevance to training and awareness

PEP clarifications and openness towards the supervisory authority

Authority / court
Eidgenössische Finanzmarktaufsicht (FINMA)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
Schweizer Geldwäschereirecht; Gewinneinziehung und Auskunftspflicht nach Finanzmarktaufsichtsrecht (laut FINMA)
Action
Disgorgement of profits
Status of proceedings
unknown
Sector
Financial services and insurance
Published
25 Mar 2024

Original amount 3,900,000 CHF, converted at the ECB reference rate of 25 Mar 2024.

Sources

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11 Mar 2024 a German major bankBaFin fines a major bank €1.45m for supervisory failings in AML compliance GermanyCustomer due diligenceanonymised €1.45m

BaFin (German Federal Financial Supervisory Authority) imposed two fines of 375,000 EUR and 1,075,000 EUR, 1,450,000 EUR in total, on a German major bank, also as universal successor of a direct bank merged into it. Owing to inadequate supervision, employees had not updated customer data on time or sufficiently, internal safeguards were inadequate, and enhanced due diligence was insufficiently applied in three cases. The decision of 11 March 2024 has been final since 28 March 2024.

What organisations can take from it

Work instructions on updating customer data are only sufficient if management effectively monitors compliance with them.

Relevance to training and awareness

Updating customer data regularly and applying enhanced due diligence

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
§ 130 Abs. 1 OWiG i. V. m. § 56 Abs. 1 S. 1 Nr. 3, Nr. 20, Nr. 32, Nr. 34 und Nr. 35 GwG
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 within the company (§ 130 OWiG, German Administrative Offences Act): inadequate oversight enabled the employees' breaches.
Published
22 Apr 2024

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8 Mar 2024 a small Swiss bankFINMA revokes a small Swiss bank's licence and later opens bankruptcy proceedings SwitzerlandOrganisational requirementsanonymised Order

The bank repeatedly breached capital requirements and organisational and risk-management requirements, kept faulty accounts, breached duties to provide information and report, and despite a ban on risk-increasing business took on higher-risk client relationships without clarifying their background; the deficiencies persisted despite measures already ordered in 2022. On 8 March 2024 the Eidgenössische Finanzmarktaufsicht (FINMA, Swiss Financial Market Supervisory Authority) revoked the bank's licence and found that it no longer offered the guarantee of irreproachable business conduct; because minimum capital was clearly undershot and over-indebtedness was feared, FINMA opened bankruptcy proceedings on 13 June 2024. At that time the licence revocation was under appeal before the Federal Administrative Court.

What organisations can take from it

Supervisory requirements must be implemented on time; a firm that takes on new risks while deficiencies remain open will ultimately lose its licence.

Relevance to training and awareness

Capital, organisation and due diligence at small banks

Authority / court
Eidgenössische Finanzmarktaufsicht (FINMA)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Bankenaufsichtsrecht: Eigenmittelvorschriften, Organisation und Risikomanagement, Sorgfaltspflichten zur Geldwäschereibekämpfung; Bewilligungsentzug
Action
Order
Status of proceedings
under appeal
Sector
Financial services and insurance
Employees
50 to 249
Repeat case
yes
Published
13 Jun 2024
Sources

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1 Mar 2024 a Swiss commodities trading houseTrading house convicted: around 86.7 million CHF over corruption in Ecuador's oil business SwitzerlandBribery of public officialsanonymised €90.5m

The Geneva-based commodities trading house failed to take all reasonable organisational precautions to prevent foreign public officials from being bribed on its behalf in connection with the Ecuadorian oil industry from 2013 to 2017. The Office of the Attorney General of Switzerland (BA) – in coordination with US authorities – ordered the trading house to pay around 86.7 million CHF, of which 4.3 million CHF is a fine.

What organisations can take from it

Commodities traders must scrutinise payments to intermediaries in government business without gaps – the confiscation of profits far exceeds the fine.

Relevance to training and awareness

Payments via intermediaries to state-owned oil companies

Authority / court
Bundesanwaltschaft (BA)
Area of law
Bribery and corruption · Bribery of public officials
Legal basis
Art. 102 StGB (Unternehmensverantwortlichkeit) i. V. m. Bestechung fremder Amtsträger
Action
Fine
Status of proceedings
unknown
Sector
Energy and utilities
Culpability
intentional
Published
1 Mar 2024

Original amount 86,700,000 CHF, converted at the ECB reference rate of 1 Mar 2024.

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1 Mar 2024 a German aircraft engine manufacturerEngine manufacturer: inside information not disclosed without delay GermanyDisclosure and reporting obligationsanonymised overturned

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

What organisations can take from it

Document the ad hoc assessment in such a way that the company can later substantiate its decision on the timing and content of a disclosure.

Relevance to training and awareness

Ad hoc disclosure: recognising inside information and disclosing it without delay

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Art. 17 Abs. 1 UAbs. 1 MAR
Action
Fine
Status of proceedings
overturned
Sector
Manufacturing and mechanical engineering
Published
20 Mar 2024

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

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19 Feb 2024 an Austrian supplier of functional and protective clothingBundeskartellamt: €783,900 on protective clothing supplier for resale price maintenance GermanyCartels and collusionanonymised €783,900

The Bundeskartellamt (Federal Cartel Office) fined the Austrian supplier of functional and protective clothing 783,900 EUR because, from early 2016 to the end of November 2021, it had agreed with specialist retailers in Germany that their resale prices – in store and online – should as far as possible match the recommended retail price and that cash discounts should generally not be granted. The case was triggered by a retailer's cooperation request; the authority used requests for information under Section 82b GWB (German Competition Act), and the fining decision is final following a settlement.

What organisations can take from it

Manufacturers may only recommend prices to retailers; agreements designed to prevent discounts or prices below the recommended price attract fines.

Relevance to training and awareness

Resale price maintenance in specialist and online retail

Authority / court
Bundeskartellamt
Area of law
Competition law · Cartels and collusion
Action
Fine
Status of proceedings
final
Sector
Manufacturing and mechanical engineering
Mitigating circumstances
Prompt, comprehensive and cooperative replies to two requests for information; agreement to a settlement.
Published
13 Mar 2024

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8 Feb 2024 a German major bankBaFin fines a major bank €50,000 for flawed reporting of an IT security incident GermanyIncident reporting obligationsanonymised €50,000

BaFin (German Federal Financial Supervisory Authority) imposed a fine of 50,000 EUR on a German major bank because the bank had given it incorrect information about a major customer-relevant IT security incident affecting its payment services in 2023 and had informed it considerably late. The decision of 8 February 2024 is final.

What organisations can take from it

IT incident reports must be fast and accurate; incorrect information given to the supervisor is sanctioned in its own right.

Relevance to training and awareness

Reporting major IT security incidents correctly and on time

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Area of law
Information security and cyber · Incident reporting obligations
Legal basis
§ 64 Abs. 3 Nr. 15 ZAG
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Published
18 Mar 2024

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6 Feb 2024 a German digital bankBaFin fines a digital bank €6.5m for systematically late suspicious activity reports GermanySuspicious activity reportsanonymised €6.5m

BaFin (Bundesanstalt für Finanzdienstleistungsaufsicht, German Federal Financial Supervisory Authority) imposed a fine of 6,500,000 EUR on a German digital bank because the institution had systematically filed money laundering suspicious activity reports with the Financial Intelligence Unit (FIU) too late. The decision of 6 February 2024 is final.

What organisations can take from it

Anyone who lets suspicious activity reports slip risks fines in the millions; reporting processes need sufficient capacity and effective deadline control.

Relevance to training and awareness

Reporting suspicious cases to the FIU without delay

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
§ 56 Abs. 1 Nr. 69, Abs. 3 GwG
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
7 Mar 2024

Checked against the official source on 2 Oct 2026 · Company name anonymised since 6 Feb 2026 · Direct link

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30 Jan 2024 Vegetable grower cheats harvest workers out of minimum wage: around 500,000 EUR in fines and confiscation GermanyMinimum wage and undeclared workanonymised €500,000

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

What organisations can take from it

Piece-rate and volume-based pay in seasonal work must reach the minimum wage per hour; deductions for accommodation and work equipment are closely scrutinised.

Authority / court
Hauptzollamt Karlsruhe (Finanzkontrolle Schwarzarbeit)
Area of law
Health and safety and employment law · Minimum wage and undeclared work
Legal basis
Mindestlohn- bzw. Tarifrecht (tariflich bestimmter Mindestlohn); Einziehung des Tatertrags
Action
Fine
Status of proceedings
unknown
Sector
Food and agriculture
Published
30 Jan 2024
Sources

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22 Jan 2024 a German port operatorPort operator: failure to publish notices on financial reports GermanyDisclosure and reporting obligationsanonymised €200,000

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

What organisations can take from it

Safeguard recurring mandatory publications by means of a checklist with named responsible persons and deadlines.

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
§ 114 Abs. 1 Satz 2 i. V. m. § 117 Nr. 1 und § 115 Abs. 1 Satz 2 i. V. m. § 117 Nr. 2 WpHG
Action
Fine
Status of proceedings
final
Sector
Transport, logistics and shipping
Published
2 Feb 2024

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22 Jan 2024 a German services companyUpper Palatinate labour inspectorate: €120,000 profit skimmed over working-time breaches GermanyWorking timeanonymised €120,000

Following a complaint, the Gewerbeaufsichtsamt (labour inspectorate) at the Regierung der Oberpfalz found considerable breaches of the Arbeitszeitgesetz (German Working Hours Act) at a services company, which had not improved at a repeat inspection. The company must pay €120,000 in skimmed-off profit, calculated from the notional gain from the repeated excess working hours; it also committed to investing at least €100,000 in improved processes.

What organisations can take from it

Anyone who fails to stop working-time breaches after a first inspection risks having the resulting gain skimmed off.

Relevance to training and awareness

Maximum working hours and labour inspectorate checks

Authority / court
Gewerbeaufsichtsamt bei der Regierung der Oberpfalz
Area of law
Health and safety and employment law · Working time
Legal basis
Arbeitszeitgesetz; Gewinnabschöpfung
Action
Disgorgement of profits
Status of proceedings
unknown
Sector
Other
Mitigating circumstances
The calculation took into account that the company had already taken noticeable measures after the last inspection.
Published
22 Jan 2024

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15 Jan 2024 a dominant Swiss delivery company and a private mail delivery companyWEKO prohibits the market leader's takeover of a private mail delivery company SwitzerlandMerger controlanonymised Order

The Wettbewerbskommission (WEKO, Swiss Competition Commission) prohibited a dominant Swiss delivery company from acquiring a private mail delivery company because the concentration would have eliminated effective competition for national addressed bulk letters over 50 grams for business customers and created or strengthened the acquirer's dominant position in further letter, parcel and newspaper delivery markets. WEKO rejected the claimed rescue takeover because another prospective buyer offered a more competitive solution; the procedural costs of CHF 98,000 are borne equally by both parties.

What organisations can take from it

A buyer invoking the rescue of an ailing competitor must show that no more competition-friendly purchaser is available.

Authority / court
Wettbewerbskommission (WEKO)
Area of law
Competition law · Merger control
Legal basis
Art. 10 Abs. 2 KG i.V.m. Art. 32 und 33 KG (Zusammenschlusskontrolle)
Action
Order
Status of proceedings
unknown
Sector
Transport, logistics and shipping
Published
19 Jan 2024

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4 Jan 2024 an Austrian association organising a football leagueFootball league organiser: €11,000 for player data left online AustriaData subject rights and transparencyanonymised €11,000

The DSB (Datenschutzbehörde, Austrian data protection authority) fined an association that organises a football league 11,000 EUR. It had taken no measures to delete player data such as name, photo, year of birth and team completely from its public online database, had not fully complied with an erasure request and had not followed a final erasure order issued by the DSB in 2021. The authority treated the lack of cooperation in the penalty proceedings as an aggravating factor.

What organisations can take from it

Anyone publishing personal data online needs a technical erasure concept from the outset, and orders of the supervisory authority must be implemented on time.

Relevance to training and awareness

Erasure concepts for publicly accessible databases

Authority / court
Datenschutzbehörde (DSB)
Area of law
Data protection · Data subject rights and transparency
Legal basis
Art. 17, Art. 25 Abs. 1 und Art. 58 Abs. 2 lit. c iVm Art. 83 Abs. 4 lit. a, Abs. 5 lit. a und Abs. 6 DSGVO
Action
Fine
Status of proceedings
final
Sector
Other
Culpability
intentional
Repeat case
no
Mitigating circumstances
No relevant previous infringements.

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19 Dec 2023 three German confectionery manufacturersDüsseldorf court: €8.35m on three confectionery makers for information exchange GermanyCartels and collusionanonymised €8.35m

The Oberlandesgericht Düsseldorf (Higher Regional Court of Düsseldorf) fined three confectionery manufacturers that had exchanged information, in committee meetings of a working group of the German confectionery industry association, on the state of their annual negotiations and special demands with food retailers (2006 to January 2008): 4.75 million EUR on the first manufacturer, 3 million EUR on the second and 0.6 million EUR on the third, 8.35 million EUR in total. Because of an unlawful delay in the proceedings, 25% of each fine is deemed enforced, leaving 6.2625 million EUR to be paid.

What organisations can take from it

Exchanging information on negotiations with retail customers in association committees is prohibited; effective compliance measures can reduce the fine.

Relevance to training and awareness

Information exchange in trade association committees

Authority / court
Oberlandesgericht Düsseldorf, 6. Kartellsenat (Urteil nach Einsprüchen gegen Bußgeldbescheide des Bundeskartellamts)
Area of law
Competition law · Cartels and collusion
Legal basis
Kartellordnungswidrigkeit (Informationsaustausch); Az. V-6 Kart 9/19 OWi
Action
Fine
Status of proceedings
unknown
Sector
Food and agriculture
Mitigating circumstances
Lesser competition-law significance of the infringement, strong buyer power of food retailers, objections limited to the penalty after a negotiated agreement, and compliance measures taken since; 25% of the fines deemed enforced because of the unlawful delay.
Published
19 Dec 2023

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12 Dec 2023 an Austrian companyCompany reports ransomware attack too late and too vaguely: €5,900 fine AustriaData breaches and data securityanonymised €5,900

The DSB (Datenschutzbehörde, Austrian data protection authority) fined a limited company 5,900 EUR because it reported a personal data breach caused by a ransomware attack, known since 6 March 2023, only on 24 April 2023, limited the notification to general statements (according to the findings, to satisfy its insurer) and did not respond to the authority's follow-up requests. The DSB treated the late notification as negligent and the other infringements as intentional. Because cooperation was still lacking afterwards, it imposed 600 EUR in a further penalty decision on 7 October 2024.

What organisations can take from it

After a cyber attack, the notification to the data protection authority must be made on time and in full, whatever the insurer requires.

Relevance to training and awareness

Reporting personal data breaches within 72 hours

Authority / court
Datenschutzbehörde (DSB)
Area of law
Data protection · Data breaches and data security
Legal basis
Art. 33 Abs. 1 und 3 sowie Art. 31 iVm Art. 83 Abs. 1 und 4 lit. a DSGVO
Action
Fine
Status of proceedings
final
Sector
Other
Culpability
intentional
Repeat case
no
Mitigating circumstances
No relevant previous infringements.

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11 Dec 2023 an Austrian bankBank deletes customer data instead of granting access: DSB fine of €9,500 AustriaData subject rights and transparencyanonymised €9,500

The DSB (Datenschutzbehörde, Austrian data protection authority) fined a bank limited by shares 9,500 EUR because it treated a customer's access request under Art. 15 GDPR internally as an erasure request, deleted her data and sent her only general information. The authority found negligence; mitigating factors were the absence of previous infringements, cooperation and insight. For the calculation the bank was placed in the turnover band of 50 to 100 million EUR.

What organisations can take from it

Data subject requests must be classified correctly before they are processed; answering an access request with erasure infringes the right of access twice over.

Relevance to training and awareness

Handling data subject access requests correctly

Authority / court
Datenschutzbehörde (DSB)
Area of law
Data protection · Data subject rights and transparency
Legal basis
Art. 12 und 15 Abs. 1 iVm Art. 83 Abs. 1 und 5 lit. b DSGVO
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Culpability
negligent
Repeat case
no
Mitigating circumstances
No previous infringements; cooperation in the proceedings, admission of the misconduct and insight.

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7 Dec 2023 a German intralogistics groupIntralogistics group: ad hoc disclosure obligation breached, fine final GermanyDisclosure and reporting obligationsanonymised €280,000

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

What organisations can take from it

Escalate potential inside information to the ad hoc disclosure committee immediately, not at the next reporting date.

Relevance to training and awareness

Ad hoc disclosure: recognising inside information and disclosing it without delay

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Art. 17 Abs. 1 UAbs. 1 MAR
Action
Fine
Status of proceedings
final
Sector
Manufacturing and mechanical engineering
Published
21 Dec 2023

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7 Dec 2023 DSB: 20,000 EUR against restaurant business over constant surveillance of kitchen and pick-up area AustriaVideo surveillanceanonymised €20,000

A restaurant company with a delivery and pick-up service (name pseudonymised) recorded workstations in the kitchen and pick-up area without interruption, even outside opening hours, and stored the recordings for 14 days. In addition, there had been no record of processing activities since 2018; the Austrian data protection authority (Datenschutzbehörde, DSB) imposed 20,000 EUR, and the penalty decision is final.

What organisations can take from it

Even small businesses may not film employees permanently – and they need a record of their processing activities.

Authority / court
Datenschutzbehörde (DSB)
Area of law
Data protection · Video surveillance
Legal basis
Art. 5 Abs. 1 lit. a und c, Art. 6 Abs. 1, Art. 30 Abs. 1 DSGVO
Action
Fine
Status of proceedings
final
Sector
Food and agriculture

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7 Dec 2023 an Austrian non-profit housing companyNon-profit housing company: €10,000 for ignoring data protection authority requests AustriaData protectionanonymised €10,000

The DSB (Datenschutzbehörde, Austrian data protection authority) fined a non-profit housing company limited by shares 10,000 EUR because it left several requests for comments in a complaint procedure between November 2021 and June 2022 unanswered, thereby breaching its duty to cooperate with the supervisory authority. The cause was internal failings in forwarding official letters; the DSB found conditional intent. Mitigating factors were the confession, the absence of previous infringements and a new control system for official mail together with staff training.

What organisations can take from it

Mail from supervisory authorities needs a reliable internal intake and forwarding process with deadline control, otherwise silence alone leads to a fine.

Relevance to training and awareness

Handling letters from the data protection authority

Missing or inadequate training played a role in the decision.

Authority / court
Datenschutzbehörde (DSB)
Area of law
Data protection
Legal basis
Art. 31 iVm Art. 58 Abs. 1 lit. a und e DSGVO; Art. 83 Abs. 4 lit. a DSGVO
Action
Fine
Status of proceedings
final
Sector
Construction and real estate
Culpability
intentional
Repeat case
no
Mitigating circumstances
No previous infringements; cooperation, insight and confession; new control system for official documents and internal data protection training.

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4 Dec 2023 a large Swiss telecommunications groupWEKO: CHF 18.4 million against telecoms group over fibre network roll-out strategy SwitzerlandAbuse of market poweranonymised €19.4m

The group expanded its fibre-optic network in such a way that competitors were not given Layer 1 access from the local exchanges. WEKO considered this to be an abuse of a dominant position, imposed a sanction of CHF 18,362,014, required the group to retrofit the network and imposed procedural costs of CHF 927,307.

What organisations can take from it

Dominant network operators must assess infrastructure decisions for their consequences for competitors' access.

Authority / court
Wettbewerbskommission (WEKO)
Area of law
Competition law · Abuse of market power
Legal basis
Art. 7 Abs. 1 i.V.m. Abs. 2 lit. a und e KG, Art. 49a Abs. 1 KG
Action
Fine
Status of proceedings
under appeal
Sector
Telecoms, IT and software
Employees
10,000 or more

Original amount 18,362,014 CHF, converted at the ECB reference rate of 4 Dec 2023.

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30 Nov 2023 an international commercial law firmHamburg: commercial law firm must record working time of employed lawyers GermanyWorking timeanonymised Order

Following complaints about regular working days lasting until 11 pm or midnight, the Hamburg occupational safety authority ordered an international commercial law firm on 30 November 2023 to record the actual working hours of its employed lawyers, to instruct them accordingly and to explain the partners' responsibility. On 18 July 2025 the Verwaltungsgericht Hamburg (Hamburg Administrative Court) upheld the recording and instruction duties for employed lawyers and set aside only the third order. The judgment is not final; the court granted leave to appeal.

What organisations can take from it

Billable client hours are not working-time records; law firms too must record the start, end and duration of work of employed lawyers.

Relevance to training and awareness

Working-time recording for employed professionals

Authority / court
Hamburger Arbeitsschutzbehörde; bestätigt durch Verwaltungsgericht Hamburg, Kammer 21
Area of law
Health and safety and employment law · Working time
Legal basis
§ 22 Abs. 3 ArbSchG i. V. m. § 3 Abs. 2 Nr. 1 ArbSchG; § 17 Abs. 2 ArbZG; §§ 12, 22 Abs. 1 ArbSchG
Action
Order
Status of proceedings
unknown
Sector
Other
Published
18 Jul 2025

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15 Nov 2023 an Austrian construction holding company and two construction companiesConstruction cartel: €9.8m on a construction holding and two construction companies AustriaCartels and collusionanonymised €9.8m

The Kartellgericht (Cartel Court) imposed a fine of 9.8 million EUR, jointly and severally, on an Austrian construction holding company and two construction companies for taking part in the construction cartel from July 2002 to October 2017. Because of their significant role in Lower Austria and Styria they were treated as main participants; collusion also concerned individual projects in other federal provinces. The acknowledgement given in the consensual termination of the proceedings and a certified compliance management system were taken into account in mitigation.

What organisations can take from it

A company that plays a leading regional role in a cartel is classed as a main participant; an effective compliance system lowers the fine but does not replace timely detection.

Relevance to training and awareness

Bid rigging in tenders

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
Culpability
intentional
Repeat case
no
Mitigating circumstances
Consensual termination of the proceedings with a full acknowledgement; certified compliance management system.
Published
5 Mar 2024

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13 Nov 2023 a German business that commissioned sales calls for energy supplyBNetzA: €285,000 fine on business that commissioned sales calls for energy supply GermanyMarketing and consentanonymised €285,000

The Bundesnetzagentur (Federal Network Agency) fined a business that had commissioned sales calls for energy supply 285,000 EUR for unlawful telephone advertising. Together with the other energy proceedings it contributed to total fines of 1.435 million EUR for unlawful telephone advertising imposed by the agency in 2023.

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
Action
Fine
Status of proceedings
unknown
Sector
Energy and utilities

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25 Oct 2023 a listed German food delivery groupBaFin fines a food delivery group €630,000 for failing to disclose inside information GermanyDisclosure and reporting obligationsanonymised €630,000

On 25 October 2023 BaFin (German Federal Financial Supervisory Authority) imposed a fine of 630,000 EUR on a listed German food delivery group because the company had not disclosed inside information. The fine is final.

What organisations can take from it

Issuers need a well-rehearsed ad hoc disclosure process that identifies price-sensitive information and publishes it immediately.

Relevance to training and awareness

Recognising inside information and disclosing it without delay

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
Media and online platforms
Published
8 Nov 2023

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14 Oct 2023 a French media groupMedia group: €120,000 fine for completing a share purchase too early AustriaMerger controlanonymised €120,000

The Kartellgericht (Cartel Court) fined a French media group 120,000 EUR for breaching the standstill obligation: the group increased its stake in another French group to 26.66% on 30 September 2020 but notified the notifiable concentration to the BWB (Federal Competition Authority) only on 14 July 2021. Mitigating factors were the absence of negative effects on competition, no overlaps in Austria, only a slight exceedance of the 25% threshold, self-reporting, cooperation and the acknowledgement.

What organisations can take from it

Even minority stakes above 25% can require notification in Austria; deal teams should check every increase against the thresholds in advance.

Relevance to training and awareness

Notification duties for share acquisitions (gun jumping)

Authority / court
Oberlandesgericht Wien als Kartellgericht (Antrag der Bundeswettbewerbsbehörde)
Area of law
Competition law · Merger control
Legal basis
§ 17 Abs. 1 KartG; § 29 Z 1 lit. a KartG
Action
Fine
Status of proceedings
final
Sector
Media and online platforms
Employees
10,000 or more
Repeat case
no
Mitigating circumstances
No negative effects on competition, no horizontal overlaps in Austria, only a slight exceedance of the 25% threshold, self-reporting, cooperation, acknowledgement.
Published
15 Feb 2024

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5 Oct 2023 a US digital groupBundeskartellamt: a digital group's commitments on user choice for cross-service data use GermanyAbuse of market poweranonymised Order

In proceedings under Section 19a of the German Competition Act (GWB), the Bundeskartellamt (Federal Cartel Office) declared commitments offered by a US digital group binding: users must in future be able to decide freely, on an informed basis and without manipulative choice screens whether the group combines or reuses across services their data from more than 25 services not covered by the DMA (including the group's email, news, assistant, contacts and TV services). The proceedings were closed to the extent of the commitments; the decision is time-limited.

What organisations can take from it

Large digital groups must make cross-service data combination depend on a genuine user choice that is not designed to manipulate.

Relevance to training and awareness

Consent to cross-service data processing and dark patterns

Authority / court
Bundeskartellamt
Area of law
Competition law · Abuse of market power
Legal basis
§ 19a Abs. 2 Satz 4 i. V. m. § 32b Abs. 1 GWB (Verpflichtungszusagen); Prüfung nach § 19a Abs. 2 S. 1 Nr. 4a GWB
Action
Order
Status of proceedings
unknown
Sector
Media and online platforms
Employees
10,000 or more
Published
5 Oct 2023

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29 Sep 2023 a Swiss online insurance ranking portalFINMA: Swiss insurance ranking portal counts as an insurance intermediary SwitzerlandCapital markets and financial supervisionanonymised Order

On its online platform the portal produces individual rankings of insurance offers through which users can request quotes; for these requests a sister company registered as an intermediary receives payments from the insurers. In enforcement proceedings the Eidgenössische Finanzmarktaufsicht (FINMA, Swiss Financial Market Supervisory Authority) found that the portal itself acts as an unaffiliated insurance intermediary even after changing the process, and ordered it to register in the intermediaries register without delay and to meet its information duties towards consumers. The ruling was not final at the time of publication.

What organisations can take from it

Platforms that rank offers side by side and earn from brokered contracts should clarify their regulatory status early rather than working around it through group structures.

Relevance to training and awareness

Regulatory classification of ranking and intermediary platforms

Authority / court
Eidgenössische Finanzmarktaufsicht (FINMA)
Area of law
Capital markets and financial supervision
Legal basis
Versicherungsaufsichtsrecht: Registrierungs- und Informationspflichten ungebundener Versicherungsvermittler
Action
Order
Status of proceedings
unknown
Sector
Media and online platforms
Published
29 Sep 2023
Sources

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28 Sep 2023 a German payment institutionBaFin fines payment institution €150,000 over identification and monitoring failures GermanyCustomer due diligenceanonymised €150,000

BaFin (German Federal Financial Supervisory Authority) imposed a fine of 150,000 EUR on a German payment institution because its supervisory and control measures were inadequate. Obligations to continuously monitor business relationships, to update customer data and to identify contracting parties were not met. The fine is final.

What organisations can take from it

Payment institutions, too, must back identification and ongoing customer monitoring with effective controls, or the company is liable for the supervisory gap.

Relevance to training and awareness

Identifying contracting parties and keeping customer data up to date

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
§ 130 Abs. 1 OWiG i. V. m. bußgeldbewehrten Pflichten des GwG (Aktualisierung von Kundendaten, Identifizierung der Vertragspartner)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Liability of senior managers
The fine is based on a breach of the duty of supervision under § 130 OWiG (German Administrative Offences Act).
Published
28 Sep 2023

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22 Sep 2023 a German outdoor retailerHamburg: order to record working time against outdoor retailer upheld by court GermanyWorking timeanonymised Order

Following an anonymous complaint about Sunday work and overlong working days, the Hamburg Amt für Arbeitsschutz (Office for Occupational Safety) ordered one of Europe's largest outdoor retailers on 22 September 2023 to record the actual working hours of all employees, including those on trust-based working time, with start, end and duration, and to submit records. On 21 August 2024 the Verwaltungsgericht Hamburg (Hamburg Administrative Court) largely dismissed the action, finding § 22(3) sentence 1 no. 1 ArbSchG (German Occupational Safety and Health Act) a sufficient legal basis; only part of one item had become moot.

What organisations can take from it

Trust-based working time does not exempt from time recording; occupational safety authorities can enforce it by order without waiting for new legislation.

Relevance to training and awareness

Duty to record working time even under trust-based working time

Authority / court
Amt für Arbeitsschutz Hamburg (Behörde für Justiz und Verbraucherschutz); bestätigt durch Verwaltungsgericht Hamburg, Kammer 15
Area of law
Health and safety and employment law · Working time
Legal basis
§ 22 Abs. 3 Satz 1 Nr. 1 ArbSchG i. V. m. § 3 Abs. 2 Nr. 1 ArbSchG (Aufzeichnungsanordnung); § 17 Abs. 4 ArbZG (Vorlage von Arbeitszeitaufzeichnungen)
Action
Order
Status of proceedings
unknown
Sector
Retail and e-commerce
Published
21 Aug 2024

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13 Sep 2023 a German sugar groupSugar cartel: €4.2m fine on a sugar group for sharing the market in 2006 AustriaCartels and collusionanonymised €4.2m

The Kartellgericht (Cartel Court) fined a German sugar group 4.2 million EUR because, in a telephone call on 22 February 2006, it had agreed with another sugar producer to share the Austrian market for industrial sugar from February to October 2006. The Bundeswettbewerbsbehörde (BWB, Federal Competition Authority) had applied for considerably higher fines in 2010; after the OGH (Supreme Court) set aside the dismissal of the fine application on 21 October 2022, the proceedings ended in a settlement.

What organisations can take from it

A single telephone call pressing a competitor to stay out of a market is market sharing liable to a fine, even years later.

Relevance to training and awareness

Territorial agreements between competitors by telephone

Authority / court
Oberlandesgericht Wien als Kartellgericht (Antrag der Bundeswettbewerbsbehörde)
Area of law
Competition law · Cartels and collusion
Legal basis
Art. 101 AEUV und § 1 KartG 2005; § 29 Z 1 lit. a und d KartG 2005
Action
Fine
Status of proceedings
final
Sector
Food and agriculture
Repeat case
no
Mitigating circumstances
The court took into account the company's economic situation in the last two financial years and the long duration of the proceedings; the group accepted the facts and the amount of the fine.
Published
9 Apr 2024

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2 Aug 2023 BlnBDI: 215,000 EUR for ‘critical’ list of employees on probation GermanyEmployee dataanonymised €215,000

On the instructions of the management, a supervisor kept a spreadsheet of all employees on probation and justified the classification ‘critical’ with, among other things, health information, psychotherapy and interest in setting up a works council. The Berlin Commissioner for Data Protection and Freedom of Information (BlnBDI) imposed a total of 215,000 EUR, of which around 40,000 EUR related to the failure to involve the data protection officer, a late breach notification and the incomplete record of processing activities; the decision was not final at the time of publication.

What organisations can take from it

Managers may base personnel decisions only on performance- and conduct-related data – health or interest in a works council belong on no list.

Relevance to training and awareness

Managers' handling of employee data

Authority / court
Berliner Beauftragte für Datenschutz und Informationsfreiheit (BlnBDI)
Area of law
Data protection · Employee data
Legal basis
DSGVO (Rechtmäßigkeit der Verarbeitung von Beschäftigten- und Gesundheitsdaten)
Action
Fine
Status of proceedings
unknown
Liability of senior managers
The list was kept on the instructions of the management.
Published
2 Aug 2023

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26 Jul 2023 a German payment service providerBaFin bars payment provider from high-risk merchant transactions and new clients GermanyCustomer due diligenceanonymised Order

On 26 July 2023 BaFin (German Federal Financial Supervisory Authority) prohibited a German payment service provider from processing transactions for certain business customers in a high-risk portfolio and ordered a ban on new customers in that area. A special audit had found serious deficiencies in enhanced due diligence, in particular in assessing online merchants' business models during onboarding and in their ongoing monitoring. The measure has been final since 29 August 2023.

What organisations can take from it

Onboarding high-risk merchants without applying enhanced due diligence can lead the supervisor to ban transactions and new business.

Relevance to training and awareness

Risk-based vetting and monitoring of merchants in the acquiring business

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
§ 51 Abs. 2 S. 1 und 2 GwG; Veröffentlichung nach § 57 Abs. 1 GwG
Action
Order
Status of proceedings
final
Sector
Financial services and insurance
Published
7 Sep 2023

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26 Jul 2023 a German drugstore chainKarlsruhe court bans drugstore chain's 'climate/environmentally neutral' claims GermanyMisleading environmental and sustainability claimsanonymised Order

On an action by Deutsche Umwelthilfe, the Landgericht Karlsruhe (Karlsruhe Regional Court) ordered a German drugstore chain to stop advertising liquid soap, sun lotion and shower cream on the packaging as 'climate neutral' and a washing-up liquid as an 'environmentally neutral product'. In the court's view, the packaging of two of the products lacked essential information on the term; moreover, CO2 offsetting via, among other things, a time-limited forest protection project could in principle not deliver the promised lasting climate neutrality.

What organisations can take from it

Anyone advertising climate neutrality through offsetting must explain on the packaging itself what is offset and must not promise a permanent effect that time-limited projects cannot deliver.

Relevance to training and awareness

Climate-neutral claims based on CO2 offsetting

Authority / court
Landgericht Karlsruhe, Kammer für Handelssachen
Area of law
Environment and sustainability · Misleading environmental and sustainability claims
Legal basis
§ 5 Abs. 1 Satz 1, Abs. 2 Nr. 1 UWG; § 5a Abs. 1 UWG
Action
Order
Status of proceedings
unknown
Sector
Retail and e-commerce
Employees
10,000 or more
Published
26 Jul 2023

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24 Jul 2023 a Swiss major bankHedge fund collapse: FINMA finds serious risk management failings at major bank SwitzerlandOrganisational requirementsanonymised Order

The bank held a position of 24 billion USD vis-à-vis a hedge fund, responded inadequately to limit breaches and paid out a further 2.4 billion USD shortly before the collapse. FINMA found serious and systematic breaches of organisational requirements and ordered the bank's legal successor to introduce group-wide position limits and risk-based remuneration.

What organisations can take from it

Escalate concentration risks and limit breaches on a mandatory basis – remuneration must not ignore the risks taken.

Authority / court
Eidgenössische Finanzmarktaufsicht (FINMA)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Bankengesetz (Organisations- und Risikomanagementpflichten)
Action
Order
Status of proceedings
unknown
Sector
Financial services and insurance
Liability of senior managers
Measures against individuals are not reported here.
Sources

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12 Jul 2023 a German fashion groupFashion group: notice on the 2021 annual financial report published too late GermanyDisclosure and reporting obligationsanonymised €112,000

The fashion group had not announced in time from when and at which internet address the 2021 annual financial report was publicly available. The fine notice is final.

What organisations can take from it

Enter recurring disclosure obligations such as the notice announcement in the financial calendar with a deadline and a responsible person.

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
§ 114 Abs. 1 Satz 2 WpHG
Action
Fine
Status of proceedings
final
Sector
Retail and e-commerce
Published
25 Jul 2023

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 12 Jul 2025 · Direct link

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3 Jul 2023 a Swiss landfill operatorWEKO sanctions landfill operator for abuse of a dominant position SwitzerlandAbuse of market poweranonymised Fine

According to WEKO's findings, the operator of a landfill in the canton of Basel-Landschaft abused its dominant position (Art. 7 para. 2 lit. b KG (Swiss Cartel Act), discrimination against trading partners). The sanction is between CHF 762,048 and 1,143,072 (exact amount redacted in the published version); in addition, there are procedural costs of CHF 196,530.

What organisations can take from it

Regional infrastructure such as landfills can also be dominant – prices and acceptance conditions must be non-discriminatory.

Authority / court
Wettbewerbskommission (WEKO)
Area of law
Competition law · Abuse of market power
Legal basis
Art. 7 Abs. 1 und Abs. 2 lit. b KG, Art. 49a Abs. 1 KG
Action
Fine
Status of proceedings
unknown
Sector
Construction and real estate

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28 Jun 2023 a German business that commissioned sales calls for energy supplyBNetzA: €275,000 fine on business that commissioned sales calls for energy supply GermanyMarketing and consentanonymised €275,000

The Bundesnetzagentur (Federal Network Agency) fined a business that had commissioned sales calls for energy supply 275,000 EUR for unlawful telephone advertising. According to the agency's annual review, callers in the 2023 energy cases frequently pretended to be from the current supplier or a price comparison site.

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
Action
Fine
Status of proceedings
unknown
Sector
Energy and utilities

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26 Jun 2023 a German railway groupBundeskartellamt orders German railway group to open up to mobility platforms GermanyAbuse of market poweranonymised Order

The Bundeskartellamt (Federal Cartel Office) found that a railway group abuses its dominant position vis-à-vis digital mobility platforms and, by a cease-and-desist order, required it to remove advertising bans, vertical price requirements and far-reaching discount bans from its contracts, to pay the platforms a fee for booking, payment processing and brokering, and to grant non-discriminatory real-time access to delay and cancellation data. The group appealed; in interim proceedings the Oberlandesgericht Düsseldorf (Higher Regional Court of Düsseldorf) largely upheld the enforceability on 8 March 2024 but provisionally suspended the requirement on minimum fee levels.

What organisations can take from it

A dominant supplier with its own sales platform must not hold back competing intermediaries through contract clauses or withheld data.

Relevance to training and awareness

Obstruction of distribution partners by dominant companies

Authority / court
Bundeskartellamt
Area of law
Competition law · Abuse of market power
Legal basis
§ 32 Abs. 1 GWB; Art. 102 AEUV, § 19 Abs. 1, Abs. 2 Nr. 1 GWB, § 20 Abs. 1a GWB
Action
Order
Status of proceedings
under appeal
Sector
Transport, logistics and shipping
Employees
10,000 or more
Published
28 Jun 2023

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15 Jun 2023 a German football clubCustoms Munich: around €200,000 confiscated from football club over minimum wage GermanyMinimum wage and undeclared workanonymised €200,000

A football club employed staff in its youth academy from 2016 to 2021 on a €450 mini-job basis although they actually worked far more hours; minimum-wage and record-keeping duties were breached. The Hauptzollamt München (Munich main customs office) issued a confiscation order of around €200,000; in addition, around €45,500 in social security contributions and late-payment surcharges are being reclaimed.

What organisations can take from it

For mini-jobs the hours actually worked count; anyone allowing more hours than agreed must record them and pay the minimum wage for them.

Relevance to training and awareness

Mini-jobs: actual hours count, not contractual hours

Authority / court
Hauptzollamt München
Area of law
Health and safety and employment law · Minimum wage and undeclared work
Legal basis
Mindestlohngesetz (Mindestlohn, Aufzeichnungspflicht); Einziehungsbescheid
Action
Disgorgement of profits
Status of proceedings
unknown
Sector
Other
Published
15 Jun 2023
Sources

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31 May 2023 BlnBDI: 300,000 EUR against bank over unexplained automated credit card rejection GermanyData subject rights and transparencyanonymised €300,000

A bank (name not published) rejected an online credit card application algorithmically and, despite enquiries, refused to give the customer a comprehensible explanation of which data and criteria led to the rejection. The Berlin Commissioner for Data Protection and Freedom of Information (BlnBDI) imposed 300,000 EUR; the bank cooperated and accepted the decision.

What organisations can take from it

Companies that make automated decisions must be able to explain to data subjects in the individual case which factors were decisive.

Authority / court
Berliner Beauftragte für Datenschutz und Informationsfreiheit (BlnBDI)
Area of law
Data protection · Data subject rights and transparency
Legal basis
Art. 22 Abs. 3, Art. 5 Abs. 1 lit. a, Art. 15 Abs. 1 lit. h DSGVO
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Extensive cooperation; fine decision accepted.
Published
31 May 2023

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17 May 2023 a Swiss crypto foundation in bankruptcyFINMA: Swiss crypto foundation sold tokens without the required licence SwitzerlandCapital markets and financial supervisionanonymised Other

In 2021 the foundation sold its own tokens to around 500 private individuals for around EUR 3 million in an initial coin offering, although the announced learning platform with marketplace never went live; the Eidgenössische Finanzmarktaufsicht (FINMA, Swiss Financial Market Supervisory Authority) classed the token as a hybrid token with the character of a security and found that the foundation, together with its founder, had acted without authorisation as a securities firm and had also acted without authorisation as a financial intermediary, and had breached its duty to provide information. Because bankruptcy proceedings had already been opened against the foundation in March 2023 owing to over-indebtedness, FINMA only formally established the serious breach of supervisory law. The ruling was not final at the time of publication.

What organisations can take from it

Anyone selling tokens to the public must first establish whether they count as securities or means of payment and require a licence.

Relevance to training and awareness

Licensing requirements for token sales (ICOs)

Authority / court
Eidgenössische Finanzmarktaufsicht (FINMA)
Area of law
Capital markets and financial supervision
Legal basis
Finanzmarktrecht: unerlaubte Tätigkeit als Wertpapierhaus und als Finanzintermediärin; Auskunftspflicht gegenüber der FINMA
Action
Other
Status of proceedings
unknown
Sector
Financial services and insurance
Published
17 May 2023
Sources

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2 May 2023 a German brewery holding companyDüsseldorf Higher Regional Court: 50 million EUR fine on brewery holding in beer cartel GermanyCartels and collusionanonymised €50m

The Oberlandesgericht Düsseldorf (Higher Regional Court of Düsseldorf) fined a brewery holding company 50 million EUR for an unlawful exchange of information: in March 2007 its then managing director had discussed, on the fringes of a trade fair, an imminent beer price rise of around six euros per hectolitre with senior staff of several other breweries and later used that knowledge in the 2008 price increase. The Bundeskartellamt (Federal Cartel Office) had initially imposed 62 million EUR in 2013/2014; after the case was discontinued as time-barred (2019) and that ruling was set aside by the Bundesgerichtshof (Federal Court of Justice) (2020), the court ruled in a new trial on the basis of a negotiated agreement.

What organisations can take from it

A single conversation about planned price rises on the fringes of a trade fair can trigger a fine running into tens of millions.

Relevance to training and awareness

Exchange of information between competitors at industry meetings

Authority / court
Oberlandesgericht Düsseldorf, 6. Kartellsenat (Urteil nach Einspruch gegen Bußgeldbescheid des Bundeskartellamts)
Area of law
Competition law · Cartels and collusion
Legal basis
Kartellordnungswidrigkeit (Informationsaustausch); Az. V-6 Kart 1/20 (OWi)
Action
Fine
Status of proceedings
unknown
Sector
Food and agriculture
Mitigating circumstances
Negotiated agreement, long duration of the proceedings and a single infringement dating back many years; the nationwide effect counted against the company.
Published
2 May 2023

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27 Apr 2023 a Swiss security technology providerPenalty order: CHF 81m against security technology provider for bribery in South America SwitzerlandBribery of public officialsanonymised €82.1m

Because of deficiencies in corporate governance, risk management and compliance, employees of a Swiss security technology provider were able to bribe public officials in connection with business in Brazil, Colombia and Venezuela. The Bundesanwaltschaft (BA, Office of the Attorney General of Switzerland) convicted the company by summary penalty order and imposed a fine of CHF 1,000,000 and a compensatory claim of CHF 80,000,000, CHF 81 million in total. The penalty order against the company is final because the company waived its right to object.

What organisations can take from it

Anyone selling to state bodies in high-risk markets needs effective sales controls, or a large compensatory claim will follow the fine.

Relevance to training and awareness

Bribery of foreign public officials in sales; compliance organisation

Authority / court
Bundesanwaltschaft (BA)
Area of law
Bribery and corruption · Bribery of public officials
Legal basis
Art. 102 Abs. 2 StGB i.V.m. Art. 322septies StGB; Ersatzforderung nach Art. 71 Abs. 1 StGB
Action
Fine
Status of proceedings
final
Sector
Other
Published
27 Apr 2023

Original amount 81,000,000 CHF, converted at the ECB reference rate of 27 Apr 2023.

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12 Apr 2023 a German call centreBNetzA: second €285,000 fine of 2023 on a call centre over energy sales calls GermanyMarketing and consentanonymised €285,000

The Bundesnetzagentur (Federal Network Agency) fined another call centre marketing energy supply 285,000 EUR for unlawful telephone advertising. It is one of the four 2023 energy proceedings in which, according to the agency, callers often concealed the real purpose of the call and asked for meter data.

What organisations can take from it

Call centres need verifiable consent for every number they dial and must honour requests to stop calling immediately.

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
unknown
Sector
Other

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27 Mar 2023 three Austrian construction companiesConstruction cartel: €27.15m fine on three Austrian construction companies AustriaCartels and collusionanonymised €27.2m

The Kartellgericht (Cartel Court) imposed a fine of 27.15 million EUR, jointly and severally, on three Austrian construction companies for taking part in the Austrian construction cartel. From at least July 2002 to October 2017, prices were fixed, markets shared and information exchanged in public and private tenders for building and civil engineering across large parts of Austria, partly through unlawful consortia and bidding groups. Reductions were granted for cooperation as leniency applicant, the acknowledgement, a certified compliance system and a reorganisation.

What organisations can take from it

Bidders must stop any contact with competitors about live tenders; practices handed down by predecessors are a typical cartel risk in sales.

Relevance to training and awareness

Bid rigging in public and private tenders

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 Z 1 lit. a und d KartG
Action
Fine
Status of proceedings
final
Sector
Construction and real estate
Repeat case
no
Mitigating circumstances
Cooperation as leniency applicant (§ 11b WettbG, Austrian Competition Act), consensual termination with acknowledgement, certified compliance system, reorganisation.
Published
21 Mar 2024

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28 Feb 2023 a Swiss major bankFINMA: Swiss major bank seriously breached supervisory law over supply-chain finance funds SwitzerlandOrganisational requirementsanonymised Order

The bank had launched four supply-chain finance funds with companies of an external financing group, which were closed in March 2021 holding around USD 10 billion of client money; the Eidgenössische Finanzmarktaufsicht (FINMA, Swiss Financial Market Supervisory Authority) found that the bank had in practice left the selection and review of receivables to the partner, had warnings handled by functions that were not independent and gave FINMA partly incorrect information, and classed this as a serious breach of its duties regarding risk management and organisation. FINMA ordered that the executive board periodically review the around 500 most important business relationships for counterparty risks and that the responsibilities of the around 600 most senior managers be recorded in writing; an audit agent monitors implementation.

What organisations can take from it

Anyone distributing a partner's products under their own name must assess the risks themselves and have warnings investigated independently.

Relevance to training and awareness

Risk management for partner products; handling internal warnings

Authority / court
Eidgenössische Finanzmarktaufsicht (FINMA)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Finanzmarktaufsichtsrecht: Pflichten zu Risikomanagement und angemessener Betriebsorganisation; Pflichten als Asset Managerin
Action
Order
Status of proceedings
unknown
Sector
Financial services and insurance
Employees
10,000 or more
Liability of senior managers
FINMA opened four enforcement proceedings against former managers of the bank and requires a responsibilities document for the most senior managers in future.
Published
28 Feb 2023
Sources

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21 Feb 2023 a German call centreBNetzA: €285,000 fine on call centre over disguised sales calls for energy contracts GermanyMarketing and consentanonymised €285,000

The Bundesnetzagentur (Federal Network Agency) fined a call centre marketing energy supply 285,000 EUR for unlawful telephone advertising. According to the agency's annual review, callers in the 2023 energy cases often posed as the customer's current supplier or as a price comparison site and asked for the meter number or meter reading.

What organisations can take from it

Call centres need verifiable consent for every number they dial and must honour requests to stop calling immediately.

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
unknown
Sector
Other

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20 Dec 2022 a German call centreBNetzA: €142,000 fine on call centre over unlawful sales calls for telecoms services GermanyMarketing and consentanonymised €142,000

The Bundesnetzagentur (Federal Network Agency) fined a call centre that marketed telecommunications services 142,000 EUR for unlawful telephone advertising. The official list states only the role, the product advertised and the amount.

What organisations can take from it

Call centres need verifiable consent for every number they dial and must honour requests to stop calling immediately.

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
unknown
Sector
Other

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7 Dec 2022 four German road construction companiesBundeskartellamt: fines on four road builders for bid rigging GermanyCartels and collusionanonymised Fine

The Bundeskartellamt (Federal Cartel Office) fined four construction companies from the same city a total of almost 1 million EUR. Between January 2012 and February 2018 (one of the companies until summer 2017) they had agreed at recurring meetings, for several hundred road-works tenders issued by the city (contract volume around 18 million EUR), which of them would submit the lowest bid while the others bid higher. The fining decisions were issued between September and December 2022 by way of settlement and are final; a further road construction company, as leniency applicant, was granted immunity from fines.

What organisations can take from it

Agreeing with competitors on who wins public tenders can lead to fines years later, once one participant cooperates with the authority as a leniency applicant.

Relevance to training and awareness

Bid rigging in public tenders

Authority / court
Bundeskartellamt
Area of law
Competition law · Cartels and collusion
Action
Fine
Status of proceedings
final
Sector
Construction and real estate
Mitigating circumstances
All four companies cooperated in the investigation and agreed to a settlement.
Published
15 Feb 2023

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2 Dec 2022 a Swiss services company of an electrical engineering groupSwiss Attorney General fines group company over bribery in South Africa SwitzerlandBribery of public officialsanonymised €4.07m

From 2013 employees of an electrical engineering group set up a bribery scheme in which inflated payments to subcontractors were used to channel benefits to public officials in South Africa and win contracts for the construction of a coal-fired power station (bribes of at least CHF 1.3 million, contracts worth at least USD 200 million). By summary penalty order, the Bundesanwaltschaft (BA, Office of the Attorney General of Switzerland) convicted a Swiss services company of the group for failing to take all reasonable organisational measures to prevent this, fined it CHF 4,000,000 (statutory maximum CHF 5 million) and ordered it to pay procedural costs of CHF 50,000. The BA waived a compensatory claim because the group had already paid USD 104 million to South Africa in 2020.

What organisations can take from it

Payments to subcontractors in high-risk countries must be checked for genuine consideration and reasonableness, or the company is liable for missing safeguards.

Relevance to training and awareness

Bribery through subcontractors and third parties in foreign business

Authority / court
Bundesanwaltschaft (BA)
Area of law
Bribery and corruption · Bribery of public officials
Legal basis
Art. 102 Abs. 2 StGB i.V.m. Art. 322septies StGB
Action
Fine
Status of proceedings
unknown
Sector
Manufacturing and mechanical engineering
Mitigating circumstances
Cooperation taken into account as mitigating; no compensatory claim because of a USD 104 million settlement payment already made to South Africa in 2020.
Published
2 Dec 2022

Original amount 4,000,000 CHF, converted at the ECB reference rate of 2 Dec 2022.

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1 Dec 2022 a German digital bankBaFin fines a digital bank €3.75m for breaches of the Money Laundering Act GermanyMoney laundering and terrorist financinganonymised €3.75m

By decision of 1 December 2022, BaFin (German Federal Financial Supervisory Authority) imposed fines totalling 3,751,500 EUR on a German digital bank for breaches of the Geldwäschegesetz (GwG, German Money Laundering Act). The notice cites § 56(1) no. 59 GwG in its 2017 version and § 56(1) no. 69 GwG in its 2020 version but does not describe the breaches in more detail. The decision has been final since 13 December 2022.

What organisations can take from it

Even where the supervisor does not describe the breaches in detail, the case shows that breaches of Money Laundering Act duties can lead to fines in the millions.

Relevance to training and awareness

Embedding Money Laundering Act obligations within the institution

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Area of law
Money laundering and terrorist financing
Legal basis
§ 56 Abs. 1 Nr. 59 GwG (Fassung vom 26.06.2017); § 56 Abs. 1 Nr. 69 GwG (Fassung vom 01.01.2020)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
21 Dec 2022

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23 Nov 2022 four Austrian construction firmsConstruction cartel: €26.33m fine on four Austrian construction firms AustriaCartels and collusionanonymised €26.3m

The Kartellgericht (Cartel Court) fined four Austrian construction firms 26.33 million EUR. From July 2002 to October 2017 they took part in price fixing, market sharing and information exchange in building and civil engineering tenders in seven federal provinces, partly through unlawful consortia and bidding groups. The fine was based on a settlement; the Cartel Court rejected a later application by the companies to correct the decision, and the Oberster Gerichtshof (OGH, Supreme Court) upheld that ruling.

What organisations can take from it

Consortia and joint bids with competitors need a documented competition law review before they are formed.

Relevance to training and awareness

Bid rigging and bidding consortia

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 Z 1 lit. a und d KartG
Action
Fine
Status of proceedings
final
Sector
Construction and real estate
Culpability
intentional
Repeat case
no
Mitigating circumstances
Consensual termination of the proceedings (with a smaller reduction because the proceedings were already pending), group-wide compliance management system, organisational separation of asphalt mixing plants, additional internal checks before forming consortia.
Published
25 Jul 2023

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22 Nov 2022 a German business that commissioned sales calls for electricity supply contractsBNetzA: €148,000 fine on business that commissioned unlawful sales calls for electricity contracts GermanyMarketing and consentanonymised €148,000

The Bundesnetzagentur (Federal Network Agency) fined a business that had commissioned sales calls for electricity supply contracts 148,000 EUR for unlawful telephone advertising. The official list gives neither the name nor further details; according to the agency, in 2022 it concentrated its investigations in nine large proceedings covering up to 3,000 complaints each.

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
Action
Fine
Status of proceedings
unknown
Sector
Energy and utilities

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22 Nov 2022 a German business that commissioned sales calls for telecommunications servicesBNetzA: €130,000 fine on business that commissioned unlawful sales calls for telecoms services GermanyMarketing and consentanonymised €130,000

The Bundesnetzagentur (Federal Network Agency) fined a business that had commissioned sales calls for telecommunications services 130,000 EUR for unlawful telephone advertising. On the same day a separate decision of 148,000 EUR was issued against the business behind a campaign for electricity supply contracts.

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
Action
Fine
Status of proceedings
unknown
Sector
Telecoms, IT and software

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11 Nov 2022 a German drugstore chainDüsseldorf Higher Regional Court: 20 million EUR fine on drugstore chain in coffee cartel GermanyCartels and collusionanonymised €20m

The Oberlandesgericht Düsseldorf (Higher Regional Court of Düsseldorf) fined a drugstore chain 20 million EUR for its part in the so-called coffee cartel – coordination between a coffee roaster and retailers on retail prices, mainly for filter coffee, between 2004 and 2008. The Bundeskartellamt (Federal Cartel Office) had imposed 5.25 million EUR at the end of 2015; a first court judgment of 30 million EUR (2018) and a later judgment dismissing the objection were both set aside by the Bundesgerichtshof (Federal Court of Justice), so that only the third trial, following a negotiated agreement, led to a judgment.

What organisations can take from it

A retailer without a leading role is still liable as a cartel participant if it coordinates retail prices with a supplier.

Relevance to training and awareness

Price coordination between manufacturer and retailer

Authority / court
Oberlandesgericht Düsseldorf, 1. Kartellsenat (Urteil nach Einspruch gegen Bußgeldbescheid des Bundeskartellamts)
Area of law
Competition law · Cartels and collusion
Legal basis
Vorsätzliche Kartellordnungswidrigkeit; Az. V 1 Kart 1/22 (OWi)
Action
Fine
Status of proceedings
unknown
Sector
Retail and e-commerce
Employees
10,000 or more
Culpability
intentional
Mitigating circumstances
Proceedings lasting more than twelve years, the objection being limited to the penalty after a negotiated agreement, no leading role in the cartel and comparatively small market significance in coffee sales.
Published
14 Nov 2022

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10 Nov 2022 a German regional state bank (Landesbank)BaFin fines a Landesbank €498,000 for failing to report suspected insider dealing GermanyMarket abuse and insider dealinganonymised €498,000

On 10 November 2022 BaFin (German Federal Financial Supervisory Authority) imposed a fine of 498,000 EUR on a German regional state bank (Landesbank). The bank had not informed BaFin without delay of a reasonable suspicion that an order in a financial instrument constituted insider dealing; this was sanctioned as a breach of the duty of supervision. The fine is final.

What organisations can take from it

Trade surveillance does not end with detection: a reasonable suspicion of insider dealing must be reported to the supervisor without delay.

Relevance to training and awareness

Detecting suspicious orders and reporting them to BaFin

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Area of law
Capital markets and financial supervision · Market abuse and insider dealing
Legal basis
§ 130 Abs. 1 OWiG i. V. m. Art. 16 Abs. 2 S. 2 MAR (Verordnung (EU) Nr. 596/2014)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Liability of senior managers
The fine is based on § 130 OWiG (German Administrative Offences Act; breach of the duty of supervision within the company).
Published
23 Nov 2022

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21 Oct 2022 OGH establishes cartel agreement between two sugar producers on deliveries to Austria AustriaCartels and collusionanonymised Other

The OGH found that a German sugar producer anonymised in the decision had agreed with a competitor in a telephone conversation on 22 February 2006 that its Slovak subsidiary would make no further exports of industrial sugar to Austria – an infringement of Art. 101 TFEU and Section 1 KartG (Austrian Cartel Act). As it was the leniency applicant, the BWB had not applied for a fine against it; the Cartel Court must decide afresh on the fine against the second producer.

What organisations can take from it

A single telephone call in which supply territories are allocated is enough to constitute a cartel infringement.

Relevance to training and awareness

Individual telephone calls with competitors about supply territories

Authority / court
Oberster Gerichtshof als Kartellobergericht (Antrag der Bundeswettbewerbsbehörde)
Area of law
Competition law · Cartels and collusion
Legal basis
§ 1 KartG 2005, Art. 101 AEUV
Action
Other
Status of proceedings
unknown
Sector
Food and agriculture
Mitigating circumstances
Leniency status of the first respondent

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 21 Oct 2024 · Direct link

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18 Oct 2022 a German defence groupBaFin fines a defence group €150,000 for late ad hoc disclosure GermanyDisclosure and reporting obligationsanonymised €150,000

On 18 October 2022 BaFin (German Federal Financial Supervisory Authority) imposed a fine of 150,000 EUR on a German defence group because the company had not disclosed inside information without delay. The fine is final.

What organisations can take from it

Delays in ad hoc disclosure are sanctioned; internal decision paths for publications must be designed accordingly.

Relevance to training and awareness

Ad hoc duty: publishing inside information without delay

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
Defence and security
Employees
10,000 or more
Published
1 Nov 2022

Checked against the official source on 2 Oct 2026 · Company name anonymised since 18 Oct 2024 · Direct link

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28 Sep 2022 a German major bankBaFin orders a major bank to take further AML measures and threatens penalty payments GermanyMoney laundering and terrorist financinganonymised Order

On 28 September 2022 BaFin (German Federal Financial Supervisory Authority) ordered a German major bank to take specific measures to prevent money laundering and terrorist financing, which the bank must adopt to implement BaFin's orders of 21 September 2018 and 15 February 2019. BaFin threatened penalty payments in the event of non-compliance. The decision has been final since 1 November 2022.

What organisations can take from it

The supervisor can follow up earlier AML orders with specific individual measures and threaten penalty payments to secure their implementation.

Relevance to training and awareness

Implementing supervisory AML orders

Authority / court
Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Area of law
Money laundering and terrorist financing
Legal basis
§ 51 Abs. 2 S. 1 GwG; Veröffentlichung nach § 57 GwG
Action
Order
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Repeat case
yes
Published
4 Nov 2022

Checked against the official source on 2 Oct 2026 · Company name anonymised since 28 Sep 2024 · Direct link

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21 Sep 2022 LfDI BW: fines against property developer and surveyor over land register data used for purchase offers GermanyMarketing and consentanonymised €55,000

A surveying engineer used the electronic land register to identify hundreds of landowners and passed the data on to a property development company, which wrote to the owners with purchase offers without informing them of the data source. The Baden-Württemberg data protection authority (LfDI BW) imposed 50,000 EUR on the property developer and 5,000 EUR on the surveyor (55,000 EUR in total); both decisions became final.

What organisations can take from it

Do not use professional access to registers such as the land register for customer acquisition or for passing data on to business partners.

Relevance to training and awareness

Purpose limitation of professional register access

Authority / court
Landesbeauftragter für den Datenschutz und die Informationsfreiheit Baden-Württemberg (LfDI BW)
Area of law
Data protection · Marketing and consent
Legal basis
Art. 6 Abs. 1 lit. f, Art. 14 DSGVO
Action
Fine
Status of proceedings
final
Sector
Construction and real estate
Published
21 Sep 2022

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 21 Sep 2024 · Direct link

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20 Sep 2022 a German e-commerce group subsidiaryBlnBDI: €525,000 over conflict of interest of a group company's data protection officer GermanyData protectionanonymised €525,000

The Berlin data protection authority fined the subsidiary of a Berlin retail group 525,000 EUR because its in-house data protection officer also managed two group service companies that processed personal data on the subsidiary's behalf, and would therefore have been supervising his own companies' work. Despite a reprimand issued in 2021, the company kept him in the role for almost a year; cooperation and ending the infringement during the proceedings were taken into account in mitigation.

What organisations can take from it

A group data protection officer must not hold a management role at affiliated service providers he or she is meant to supervise.

Relevance to training and awareness

Independence and conflicts of interest of the data protection officer

Authority / court
Berliner Beauftragte für Datenschutz und Informationsfreiheit (BlnBDI)
Area of law
Data protection
Legal basis
Art. 38 Abs. 6 Satz 2 DSGVO
Action
Fine
Status of proceedings
unknown
Sector
Retail and e-commerce
Culpability
intentional
Repeat case
yes
Mitigating circumstances
Extensive cooperation with the supervisory authority; the infringement was ended while the fine proceedings were still running.
Published
20 Sep 2022

Checked against the official source on 2 Oct 2026 · Company name anonymised since 20 Sep 2024 · Direct link

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16 Sep 2022 LG Hamburg: advertise star ratings only with the number of reviews and the period covered GermanyFake reviewsanonymised Order

A platform matching property sellers with estate agents advertised average star ratings without stating the number, period and distribution of the reviews. In an action brought by the Wettbewerbszentrale, the Regional Court of Hamburg (LG Hamburg) ordered it to cease and desist insofar as the total number and period were missing; the further claim for a breakdown by star category was dismissed by the Higher Regional Court of Hamburg (OLG Hamburg) and the BGH (judgment of 25 July 2024).

What organisations can take from it

Anyone advertising with average ratings must at least state the number of underlying reviews and the period they cover.

Relevance to training and awareness

Advertising with customer reviews

Authority / court
Landgericht Hamburg (Revision der Klägerin zum Umfang beim BGH)
Area of law
Consumer protection and online retail · Fake reviews
Legal basis
§§ 3, 5a Abs. 1, 8 UWG
Action
Order
Status of proceedings
unknown
Sector
Construction and real estate
Published
25 Jul 2024

Checked against the official source on 28 Sep 2026 · Version 5 · Company name anonymised since 16 Sep 2024 · Direct link

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