Compliance Radar

Who was sanctioned, and for what?

Fines, court rulings and incidents from Europe and North America: 718 cases from 32 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.

EUGermany Clear all filters
39cases from 1 jurisdiction
€204.8mTotal of monetary amounts (28 cases with an amount)
€416,252Median per case with an amount

Click a bar to drill down one level.

Where?

by authority
  1. Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin) 13 cases 33 % · €61.7m
  2. Bundeskartellamt 7 cases 18 % · €96.7m
  3. Bezirksregierung Arnsberg (Geldwäscheaufsicht Nichtfinanzsektor) 2 cases 5 % · €392,370
  4. Hauptzollamt Karlsruhe (Finanzkontrolle Schwarzarbeit) 2 cases 5 % · €513,731
  5. Landesdirektion Sachsen (Geldwäscheaufsicht Nichtfinanzsektor) 2 cases 5 % · €7,800
  6. Berliner Beauftragte für Datenschutz und Informationsfreiheit (BlnBDI) 1 case 3 % ·
  7. Bundesbeauftragte für den Datenschutz und die Informationsfreiheit (BfDI) 1 case 3 % · €45m
  8. Bundesgerichtshof (I. Zivilsenat) 1 case 3 % ·
  9. Bundesgerichtshof (I. Zivilsenat), Az. I ZR 170/24 1 case 3 % ·
  10. Bundesgerichtshof (I. Zivilsenat), Az. I ZR 183/24 1 case 3 % ·
  11. 8 more8 cases

What for?

by area of law

All areas of law

  1. Money laundering and terrorist financing 9 cases 23 % · €58.6m
  2. Capital markets and financial supervision 8 cases 21 % · €3.46m
  3. Competition law 7 cases 18 % · €96.7m
  4. Data protection 5 cases 13 % · €45.2m
  5. Health and safety and employment law 4 cases 10 % · €746,231
  6. Consumer protection and online retail 3 cases 8 % ·
  7. Sanctions and export control 2 cases 5 % ·
  8. Environment and sustainability 1 case 3 % ·

Who?

by sector

All sectors

  1. Construction and real estate 7 cases 18 % · €78.6m
  2. Financial services and insurance 6 cases 15 % · €58.4m
  3. Retail and e-commerce 5 cases 13 % · €6.58m
  4. Manufacturing and mechanical engineering 5 cases 13 % · €1.35m
  5. Automotive 3 cases 8 % · €12.1m
  6. Telecoms, IT and software 3 cases 8 % · €47m
  7. Transport, logistics and shipping 3 cases 8 % · €213,731
  8. Food and agriculture 2 cases 5 % · €500,000
  9. Other 2 cases 5 % ·
  10. Healthcare 1 case 3 % ·
  11. 2 more2 cases

When?

per quarter, by date of decision
Trend
PeriodCasesTotal
Q3 20230—
Q4 20232€5.08m
Q1 20243€700,000
Q2 20243€9.21m
Q3 20240—
Q4 20243€2.79m
Q1 20252€800
Q2 20255€63.3m
Q3 20253€4m
Q4 20255€45.4m
Q1 20263€426,231
Q2 20263€620,000
Q3 20267€73.3m

39 cases

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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21 Jul 2026 Maxxis International GmbH, Best4Tires Berlin GmbH, Reifen Müller GmbH & Co. KGBundeskartellamt: 11.9 million EUR over resale price maintenance in tyre distribution (Maxxis/CST) GermanyCartels and collusion €11.9m

Maxxis guaranteed wholesalers fixed margins per tyre sold of the Maxxis and CST brands, monitored prices in particular on the Tyre24 platform and intervened when prices were too low. Germany's Federal Cartel Office (Bundeskartellamt) imposed fines totalling 11.9 million EUR on three companies and one responsible individual.

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
Liability of senior managers
Fine imposed on one responsible natural person (not named)
Published
21 Jul 2026

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

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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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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

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

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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

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

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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
Sources

Checked against the official source on 25 Sep 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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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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9 Jan 2026 Bulgarian construction subcontractor: 232,500 EUR for paying below the minimum wage GermanyMinimum wage and undeclared work €232,500

A Bulgarian construction company that worked as a subcontractor for a German firm on a major construction site in the district of Tuttlingen between January and May 2023 paid below the minimum wage, recorded only the duration of working time rather than its start and end, and did not register the posting. The decisions issued in September 2025, final since the end of 2025, amount to 232,500 EUR – of which 215,000 EUR is disgorgement of the economic benefit and 17,500 EUR is imposed on the managing director (date = publication; exact date of the decision not specified).

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
Liability of senior managers
Separate fine of 17,500 EUR against the managing director.
Published
9 Jan 2026

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

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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). Karl-Ernst Hardeck is named as the person responsible for the company.

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
The announcement names Karl-Ernst Hardeck as the person responsible for the infringement

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

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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 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

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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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