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.

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

Click a bar to drill down one level.

Where?

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

What for?

by area of law

All areas of law

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

Who?

by sector

All sectors

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

When?

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

38 cases

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

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

What organisations can take from it

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

Relevance to training and awareness

Anti-money-laundering: investigating conspicuous inflows and documentation

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

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

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

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

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

What organisations can take from it

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

Authority / court
Bundesverwaltungsgericht (A-3891/2025) auf Verfügung des EDÖB vom 28.04.2025
Area of law
Data protection · Data subject rights and transparency
Legal basis
DSG Art. 6, Art. 19, Art. 31
Action
Order
Status of proceedings
final
Sector
Financial services and insurance
Published
20 Aug 2026

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

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

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

What organisations can take from it

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

Relevance to training and awareness

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Conflicts of interest and suitability checks in asset management

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Handling objections to advertising and deletion requests

Authority / court
Eidgenössischer Datenschutz- und Öffentlichkeitsbeauftragter (EDÖB)
Area of law
Data protection · Marketing and consent
Legal basis
DSG Art. 6, Art. 30 Abs. 2 lit. b, Art. 31
Action
Order
Status of proceedings
final
Sector
Retail and e-commerce
Published
26 Jun 2026

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

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

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

What organisations can take from it

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Exclusivity clauses and tying by dominant undertakings

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Cover bids and territorial agreements in regional road construction

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Anti-money laundering and PEP clients

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Customer due diligence and adverse media screening

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Buying cooperations in retail: limits of joint negotiating power

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

High-risk clients and transaction monitoring

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Cartel risks for intermediate products and active ingredients; leniency programme

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

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

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

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

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

What organisations can take from it

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

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Payments via intermediaries to employees of state-owned oil companies

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Handling access requests

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

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

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

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

What organisations can take from it

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

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

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

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

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

What organisations can take from it

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

Relevance to training and awareness

Relative market power and refusal to supply on foreign terms

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

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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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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.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 5 Aug 2026 · Direct link

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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
Sources

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 18 Jun 2026 · Direct link

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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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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.

Checked against the official source on 2 Oct 2026 · Company name anonymised since 21 May 2026 · Direct link

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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

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 1 May 2026 · Direct link

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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

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 25 Mar 2026 · Direct link

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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

Checked against the official source on 2 Oct 2026 · Company name anonymised since 8 Mar 2026 · Direct link

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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.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 1 Mar 2026 · Direct link

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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

Checked against the official source on 2 Oct 2026 · Company name anonymised since 15 Jan 2026 · Direct link

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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.

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

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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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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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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

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 3 Jul 2025 · Direct link

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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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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.

Checked against the official source on 2 Oct 2026 · Company name anonymised since 27 Apr 2025 · Direct link

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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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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.

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

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