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.
Click a bar to drill down one level.
Where?
by levelWhat for?
by area of lawAll areas of law
- Bribery and corruption 24 cases 16 % · €5.64bn
- Health and safety and employment law 17 cases 12 % · €17.3m
- Sanctions and export control 14 cases 10 % · €636.6m
- Supply chain and human rights 12 cases 8 % ·
- Environment and sustainability 12 cases 8 % · €4.24bn
- Information security and cyber 10 cases 7 % · €21.6m
- Money laundering and terrorist financing 9 cases 6 % · €363.9m
- Capital markets and financial supervision 9 cases 6 % · €443.8m
- Consumer protection and online retail 9 cases 6 % · €2.32bn
- Data protection 8 cases 5 % · €1.2bn
- 4 more23 cases
Who?
by sectorAll sectors
- Financial services and insurance 30 cases 20 % · €658.4m
- Healthcare 15 cases 10 % · €296.5m
- Food and agriculture 13 cases 9 % · €53.5m
- Automotive 11 cases 7 % · €4.26bn
- Chemicals and pharmaceuticals 11 cases 7 % · €4.99bn
- Retail and e-commerce 10 cases 7 % · €2.19bn
- Transport, logistics and shipping 8 cases 5 % · €102.3m
- Defence and security 8 cases 5 % · €432.2m
- Manufacturing and mechanical engineering 7 cases 5 % · €224.7m
- Other 7 cases 5 % · €8.02m
- 5 more27 cases
When?
per quarter, by date of decision| Period | Cases | Total |
|---|---|---|
| Q3 2023 | 3 | €66.5m |
| Q4 2023 | 3 | €913,159 |
| Q1 2024 | 6 | €1.55bn |
| Q2 2024 | 5 | €45.2m |
| Q3 2024 | 16 | €148.4m |
| Q4 2024 | 14 | €739.2m |
| Q1 2025 | 13 | €2.66bn |
| Q2 2025 | 8 | €280.1m |
| Q3 2025 | 15 | €2.3bn |
| Q4 2025 | 15 | €1.32bn |
| Q1 2026 | 13 | €390.3m |
| Q2 2026 | 14 | €5.23bn |
| Q3 2026 | 22 | €280.9m |
147 cases
22 Sep 2026 OTC Link LLCOTC Link: 575,000 USD – security policies never completed despite examination findings €501,614
From 2016 to 2025, the operator of the OTC Link ATS trading system lacked complete policies on systems security, access control and vulnerability management as required under Regulation SCI. Although the examiners of the U.S. Securities and Exchange Commission (SEC) had criticised the gaps in several examinations, drafts remained unfinished; the SEC issued a censure and imposed 575,000 USD.
Track supervisory examination findings with a deadline and a responsible person – points that remain open repeatedly become expensive.
- Authority / court
- U.S. Securities and Exchange Commission (SEC)
- Area of law
- Information security and cyber · Critical infrastructure
- Legal basis
- Regulation SCI, Rule 1001(a)(1)–(3)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Financial services and insurance
- Repeat case
- yes
Original amount 575,000 USD, converted at the ECB reference rate of 22 Sep 2026.
- SEC Censures OTC Link LLC for Repeated Compliance Failures Related to Regulation SCI (22.09.2026) Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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17 Sep 2026 FleetCor Technologies Inc. (heute Corpay Inc.)FleetCor/Corpay pays 100 million USD over hidden fees on fuel cards €87.1m
In 2023, a federal court found by way of summary judgment that the fuel card provider had charged its predominantly small business customers hidden or unauthorised fees and misrepresented savings; an appeals court upheld this in 2026. According to the FTC, the fees added up to hundreds of millions of dollars, and late fees were also charged despite punctual payment. Under the settlement resolving the administrative proceedings, FleetCor and CEO Ronald Clarke are paying 100 million USD for refunds; the order is not yet final.
Fees hidden behind links or in account documents are deemed not to have been disclosed – including vis-à-vis business customers.
- Authority / court
- Federal Trade Commission (FTC)
- Area of law
- Consumer protection and online retail · Misleading advertising and pricing
- Legal basis
- Section 5 FTC Act
- Action
- Disgorgement of profits
- Status of proceedings
- unknown
- Sector
- Financial services and insurance
- Liability of senior managers
- CEO Ronald Clarke is named in the press release as a party involved.
- Published
- 17 Sep 2026
Original amount 100,000,000 USD, converted at the ECB reference rate of 17 Sep 2026.
- FleetCor Agrees to Pay $100 Million to Resolve Administrative Action After Federal Court Finds It Violated the FTC Act Press release of an authority
- FTC Case: Fleetcor Technologies, In the Matter of (Docket 9403) Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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10 Sep 2026 Dompé U.S. Inc.Dompé U.S.: 32 million USD – Medicare patients’ co-payments covered via foundations €27.5m
From 2018 to 2021, the pharmaceutical manufacturer allegedly used two patient assistance foundations to fund Medicare beneficiaries’ co-payments for its drug Oxervate in order to promote its sales. Following a self-disclosure, Dompé paid 32 million USD.
Benefits flowing to customers via foundations or other third parties remain benefits provided by the company – donations to patient assistance programmes require strict independence.
Benefits to patients and customers via third parties
- Authority / court
- U.S. Department of Justice / U.S. Attorney's Office, District of Massachusetts
- Area of law
- Bribery and corruption · Gifts, hospitality and benefits
- Legal basis
- Anti-Kickback Statute (42 U.S.C. § 1320a-7b(b)); False Claims Act (31 U.S.C. §§ 3729 ff.)
- Action
- Other
- Status of proceedings
- final
- Sector
- Chemicals and pharmaceuticals
- Mitigating circumstances
- Self-disclosure.
Original amount 32,000,000 USD, converted at the ECB reference rate of 10 Sep 2026.
- HHS-OIG Enforcement Actions: Dompé U.S. Agrees to Pay $32M to Resolve False Claims Act Liability Relating to Self-Disclosure of Patient Kickbacks (10.09.2026) Enforcement database of an authority
- U.S. Department of Justice: Dompé U.S. Agrees to Pay $32M to Resolve False Claims Act Liability Relating to Self-Disclosure of Patient Kickbacks (10.09.2026) Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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28 Aug 2026 MSC Shipmanagement Limited; Hong Kong Spirit Shipping and Trading LimitedMSC Shipmanagement: 1.75 million USD fine for secretly discharging oily bilge water €1.5m
On board the MSC Samira III, senior engineering officers had oily bilge water pumped overboard via the sewage tank, bypassing the oily water separator, in 2024/2025, manipulated the oil content monitoring and falsified the oil record book, which was presented to the Coast Guard in Philadelphia. The operator and the owner each pleaded guilty to two counts under the Act to Prevent Pollution from Ships (APPS) and are paying a combined 1.75 million USD; in addition, there are four years of probation.
Shipping companies must actively monitor practice on board and the oil record book, because instructions given by individual officers are attributed to the company under criminal law.
MARPOL obligations on board, oil record book and reporting channels for crews
- Authority / court
- U.S. District Court for the Eastern District of Pennsylvania (Anklage: DOJ Environment and Natural Resources Division)
- Area of law
- Environment and sustainability · Waste and hazardous substances
- Legal basis
- Act to Prevent Pollution from Ships (APPS), 33 U.S.C. § 1908
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Transport, logistics and shipping
- Employees
- 10,000 or more
- Culpability
- intentional
- Liability of senior managers
- Second Engineer Mikhail Tsurikov also pleaded guilty; sentencing scheduled for 10 September 2026.
- Published
- 28 Aug 2026
Original amount 1,750,000 USD, converted at the ECB reference rate of 28 Aug 2026.
- International Shipping Companies Sentenced to Pay $1.75 Million Fine for Concealing Discharges of Oily Waste into Ocean Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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24 Aug 2026 Container Manufacturing Ltd.Small US machinery supplier exported spare parts for can presses to Russia €857,339
Between March 2023 and March 2025, the Ohio manufacturer of presses for beverage can ends (nine employees) supplied, in ten instances, spare parts for aluminium forming tools worth around 264,700 USD – partly via the UAE and Turkey – without a licence to a Russian customer whose group also supplies defence precursors. In two instances, the company acted with knowledge of the violation; it admitted the allegations, which were brought by the US Commerce Department's Bureau of Industry and Security (BIS).
Even small businesses with few employees must check tariff codes against Russia restrictions and treat deliveries via third countries as a warning sign.
HTS-based export restrictions on Russia, diversion via third countries
Missing or inadequate training played a role in the decision.
- Authority / court
- U.S. Department of Commerce, Bureau of Industry and Security (BIS)
- Area of law
- Sanctions and export control · Export control and dual-use goods
- Legal basis
- Export Administration Regulations, § 746.8(a)(5) (HTS-Codes Supplement No. 4 to Part 746), §§ 764.2(a), 764.2(e)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Manufacturing and mechanical engineering
- Employees
- Under 50
- Mitigating circumstances
- Full cooperation; compliance programme subsequently expanded with screening, an approval process and additional export control training
- Published
- 24 Aug 2026
Original amount 1,000,000 USD, converted at the ECB reference rate of 24 Aug 2026.
- BIS Reaches Administrative Enforcement Settlement with Container Manufacturing Ltd. (24.08.2026) Press release of an authority
- BIS Order Relating to Container Manufacturing Ltd. Decision of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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20 Aug 2026 IPMF LLC (NaturPak)NaturPak: $364,100 proposed after three deaths caused by bursting kettle lids €311,703
At the food plant in Janesville (Wisconsin), the lids of pressurised industrial kettles opened in February and March 2026, scalding workers with steam and hot liquid; three people died. The U.S. Occupational Safety and Health Administration (OSHA) proposed a total of $364,100 for both inspections combined, including repeat violations relating to fall protection and lockout/tagout.
After a serious accident, the technical cause must be eliminated immediately – otherwise, as here, a second similar incident may follow.
- Authority / court
- U.S. Department of Labor – Occupational Safety and Health Administration (OSHA)
- Area of law
- Health and safety and employment law · Workplace safety and accidents
- Legal basis
- Occupational Safety and Health Act of 1970; 29 CFR 1910 (u. a. Lockout/Tagout, Absturzsicherung, persönliche Schutzausrüstung)
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Food and agriculture
- Repeat case
- yes
- Published
- 20 Aug 2026
Original amount 364,100 USD, converted at the ECB reference rate of 20 Aug 2026.
Checked against the official source on 25 Sep 2026 · Direct link
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19 Aug 2026 Sioux Erosion Control Inc.DOJ: jury convicts erosion control firm of price fixing in Oklahoma road construction —
A jury found Sioux Erosion Control, co-owner BG Dale Biscoe and employee Randall David Shelton guilty of having fixed prices for erosion control services, allocated contracts regionally and rigged bids on publicly funded road construction projects in Oklahoma (more than 100 million USD) from 2017 to 2023. Sentencing was still pending.
Subcontractors in public road construction are also targeted by prosecutors – up to and including jury convictions of individual employees.
Price-fixing and territorial agreements for subcontracted services in road construction
- Authority / court
- U.S. Department of Justice, Antitrust Division
- Area of law
- Competition law · Cartels and collusion
- Legal basis
- Section 1 Sherman Act
- Status of proceedings
- unknown
- Sector
- Construction and real estate
- Liability of senior managers
- Guilty verdict against co-owner BG Dale Biscoe and employee Randall David Shelton
- Published
- 20 Aug 2026
- Jury Convicts Erosion Control Company, Executive, and Employee for Roles in $100M Price-Fixing Conspiracy Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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14 Aug 2026 Henkel AG & Co. KGaAHenkel/Liquid Nails: court blocks takeover of Loctite’s main competitor Order
Henkel wanted to buy the construction adhesive brand Liquid Nails for 725 million USD from the financial investor American Industrial Partners, thereby taking over the main competitor of its Loctite brand. After a seven-day trial, the federal court, on application by the Federal Trade Commission (FTC), issued a permanent injunction against the acquisition.
Acquiring the closest competitor carries a high risk of prohibition, even at a moderate deal volume.
- Authority / court
- U.S. District Court for the Southern District of New York (auf Antrag der FTC)
- Area of law
- Competition law · Merger control
- Legal basis
- Section 7 Clayton Act; Section 13(b) FTC Act (Permanent Injunction)
- Action
- Order
- Status of proceedings
- unknown
- Sector
- Chemicals and pharmaceuticals
- Employees
- 10,000 or more
- Published
- 17 Aug 2026
- Statement on FTC Win Blocking Loctite, Liquid Nails Construction Adhesive Merger (17.08.2026) Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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12 Aug 2026 Rice Lake Weighing Systems, Inc.Scale manufacturer Rice Lake liable for Italian subsidiary's indirect exports to Iran €52,632
In eight instances in 2019–2021, the Italian subsidiary Dini Argeo supplied weighing equipment worth around 121,500 USD to a trader in the UAE, although it knew that the goods would be passed on to a former direct Iranian customer. The parent company had passed on the Iran ban only by an English-language e-mail without explanation; the US Treasury's Office of Foreign Assets Control (OFAC) considered it a non-egregious, voluntarily self-disclosed case.
Implement sanctions requirements at foreign subsidiaries in an understandable way, in the local language and with training for all relevant employees – indirect supplies via traders are also prohibited.
Sanctions training for foreign subsidiaries, indirect supplies via third countries
Missing or inadequate training played a role in the decision.
- Authority / court
- U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC)
- Area of law
- Sanctions and export control · Breaches of sanctions and embargoes
- Legal basis
- Iranian Transactions and Sanctions Regulations, § 560.215 (Auslandstöchter von US-Personen)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Manufacturing and mechanical engineering
- Culpability
- negligent
- Repeat case
- no
- Mitigating circumstances
- Voluntary self-disclosure, immediate internal investigation, low significance for turnover, no prior violations, cooperation; subsequent training of the subsidiary's employees and screening of traders
- Published
- 12 Aug 2026
Original amount 60,764 USD, converted at the ECB reference rate of 12 Aug 2026.
- OFAC Enforcement Release: Rice Lake Weighing Systems Settles with OFAC for Iran-Related Apparent Violations (12.08.2026) Decision of an authority
- OFAC – Civil Penalties and Enforcement Information Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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10 Aug 2026 Veloxis Pharmaceuticals Inc.Veloxis: over 46 million USD – luxury trips, dinners and gifts for transplant teams Other
From 2016 to 2023, Veloxis provided transplant professionals with expensive meals and alcohol, trips and stays at luxury resorts, gifts and consultancy fees without consideration, and paid specialty pharmacies concealed remuneration in order to promote prescriptions and purchases of the immunosuppressant Envarsus XR. The company entered into a Deferred Prosecution Agreement with a criminal payment of more than 10 million USD, is paying 34.45 million USD under civil law (21,211,251 USD to the federal government, 13,238,749 USD to states) and a penalty of 1.55 million USD under the Sunshine Act (Open Payments) – the highest to date – totalling over 46 million USD.
Invitations and gifts to decision-makers must not only be limited but also fully reported to transparency registers.
Gifts, travel and hospitality for healthcare professionals; transparency reporting
- Authority / court
- U.S. Department of Justice / U.S. Attorney's Office, District of Massachusetts
- Area of law
- Bribery and corruption · Gifts, hospitality and benefits
- Legal basis
- Anti-Kickback Statute; False Claims Act; Physician Payments Sunshine Act (Open Payments)
- Action
- Other
- Status of proceedings
- final
- Sector
- Chemicals and pharmaceuticals
- DOJ: Veloxis Pharmaceuticals Agrees to Pay Over $46M to Resolve Criminal and Civil Liability for Kickback Schemes (10.08.2026) Press release of an authority
- HHS-OIG Enforcement Actions: Veloxis Pharmaceuticals Agrees to Pay Over $46M … (10.08.2026) Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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5 Aug 2026 Order Express, Inc.NYDFS: $250,000 against money transmitter Order Express over cyber deficiencies €216,375
The licensed money transmitter had no adequate policies for system updates and insufficient risk assessments under New York's cybersecurity regulation, as found by the New York State Department of Financial Services (NYDFS). The company has already remedied the deficiencies.
Even small financial service providers must keep documented patch policies and regular risk assessments.
- Authority / court
- New York State Department of Financial Services (NYDFS)
- Area of law
- Information security and cyber · Security measures and risk management
- Legal basis
- 23 NYCRR Part 500 (Cybersecurity Regulation)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Financial services and insurance
- Mitigating circumstances
- Because of its low turnover, the company was exempt from many Part 500 obligations; deficiencies already remedied.
- Published
- 5 Aug 2026
Original amount 250,000 USD, converted at the ECB reference rate of 5 Aug 2026.
- New York State Department of Financial Services Secures Cybersecurity Settlement with Order Express, Inc. Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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3 Aug 2026 UBS Financial Services Inc.FinCEN: 125 million USD against UBS Financial Services as a repeat offender €108.4m
The US Financial Crimes Enforcement Network (FinCEN) imposed 125 million USD on the broker-dealer – the highest BSA penalty against a broker-dealer to date. UBSFS admitted wilful infringements: the AML programme was inadequate, more than 50,000 foreign currency transfers totalling more than 10 billion USD were not adequately monitored and suspicious activity reports were not filed; it is already the second enforcement action after 2018.
Monitoring gaps left unremedied after an earlier enforcement action lead, the second time round, to a multiple of the original penalty.
- Authority / court
- Financial Crimes Enforcement Network (FinCEN)
- Area of law
- Money laundering and terrorist financing · Internal controls
- Legal basis
- Bank Secrecy Act (BSA)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Financial services and insurance
- Employees
- 10,000 or more
- Culpability
- intentional
- Repeat case
- yes
- Mitigating circumstances
- Up to 15 million USD (remaining amount due by 31 May 2028) may be waived to the extent that UBSFS bears the costs of the independent review of its AML programme and implements its recommendations
- Published
- 3 Aug 2026
Original amount 125,000,000 USD, converted at the ECB reference rate of 3 Aug 2026.
- FinCEN Assesses Historic $125 Million Penalty Against UBS Financial Services Inc. for Recidivist BSA Violations Press release of an authority
- FinCEN Consent Order Imposing Civil Money Penalty – UBS Financial Services Inc. (Number 2026-02) Decision of an authority
- FinCEN Enforcement Actions Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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3 Aug 2026 Zhengzhou Synear Food Co., Ltd.UFLPA list: frozen food manufacturer Zhengzhou Synear Food added Order
The U.S. Forced Labor Enforcement Task Force (FLETF) added the frozen food manufacturer to the Uyghur Forced Labor Prevention Act (UFLPA) Entity List because it works with the Xinjiang government to take in Uyghurs, Kazakhs, Kyrgyz or members of other persecuted groups under state labour transfer programmes. The company's goods are therefore presumed to have been produced with forced labour on import into the US unless the importer rebuts this.
Food importers should also check suppliers outside Xinjiang for involvement in state labour transfer programmes.
- Authority / court
- U.S. Department of Homeland Security (Forced Labor Enforcement Task Force)
- Area of law
- Supply chain and human rights · Forced and child labour
- Legal basis
- Uyghur Forced Labor Prevention Act, Section 2(d)(2)(B)(ii)
- Action
- Order
- Status of proceedings
- unknown
- Sector
- Food and agriculture
- Published
- 3 Aug 2026
- Federal Register: Notice Regarding the Uyghur Forced Labor Prevention Act Entity List (03.08.2026) Official register or notice
Checked against the official source on 25 Sep 2026 · Direct link
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3 Aug 2026 Guangxi Kelun Pharmaceutical Co., Ltd.UFLPA list: antibiotics manufacturer Guangxi Kelun Pharmaceutical added Order
The U.S. Forced Labor Enforcement Task Force (FLETF) listed the manufacturer of cephalosporin antibiotics because it sources antibiotic intermediates from Yili Chuanning Biotechnology in Xinjiang. The company's goods are therefore presumed to have been produced with forced labour on import into the US unless the importer rebuts this.
Pharmaceutical companies must be able to trace their supply chains back to active ingredient intermediates.
- Authority / court
- U.S. Department of Homeland Security (Forced Labor Enforcement Task Force)
- Area of law
- Supply chain and human rights · Forced and child labour
- Legal basis
- Uyghur Forced Labor Prevention Act, Section 2(d)(2)(B)(v)
- Action
- Order
- Status of proceedings
- unknown
- Sector
- Chemicals and pharmaceuticals
- Published
- 3 Aug 2026
- Federal Register: Notice Regarding the Uyghur Forced Labor Prevention Act Entity List (03.08.2026) Official register or notice
Checked against the official source on 25 Sep 2026 · Direct link
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3 Aug 2026 Shandong Weiqiao Pioneering Group Co., Ltd.UFLPA list: textile group Shandong Weiqiao Pioneering Group over Xinjiang cotton Order
The U.S. Forced Labor Enforcement Task Force (FLETF) added the cotton and textile producer to the Uyghur Forced Labor Prevention Act (UFLPA) Entity List because it sources cotton from Xinjiang. The company's goods are therefore presumed to have been produced with forced labour on import into the US unless the importer rebuts this.
Textile retailers need proof of origin for cotton down to the fibre, for example through isotope or traceability testing.
- Authority / court
- U.S. Department of Homeland Security (Forced Labor Enforcement Task Force)
- Area of law
- Supply chain and human rights · Forced and child labour
- Legal basis
- Uyghur Forced Labor Prevention Act, Section 2(d)(2)(B)(v)
- Action
- Order
- Status of proceedings
- unknown
- Sector
- Other
- Published
- 3 Aug 2026
- Federal Register: Notice Regarding the Uyghur Forced Labor Prevention Act Entity List (03.08.2026) Official register or notice
Checked against the official source on 25 Sep 2026 · Direct link
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30 Jul 2026 Access DX Laboratory, LLCAccess DX Laboratory: 36.4 million USD – kickbacks for unnecessary genetic tests €31.7m
The Houston laboratory, its former CEO Michael Stewart and the businessman Harold Shatz allegedly paid kickbacks and billed Medicare and Medicaid for medically unnecessary genetic tests. The three settlements add up to 36.4 million USD; the laboratory is subject to a Corporate Integrity Agreement.
Commission models for intermediaries who bring in orders or patients are a classic gateway for bribery.
Remuneration of intermediaries and referrers
- Authority / court
- U.S. Department of Justice
- Area of law
- Bribery and corruption · Commercial bribery
- Legal basis
- Anti-Kickback Statute (42 U.S.C. § 1320a-7b(b)); False Claims Act (31 U.S.C. §§ 3729 ff.)
- Action
- Other
- Status of proceedings
- final
- Sector
- Healthcare
- Liability of senior managers
- Former CEO pays under a separate settlement.
Original amount 36,400,000 USD, converted at the ECB reference rate of 30 Jul 2026.
- HHS-OIG Enforcement Actions: Texas Laboratory, Former CEO, and Florida Businessman Pay a Total of $36.4M … (30.07.2026) Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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23 Jul 2026 Orchids Builders LLCFlorida roofer: $349,754 for repeatedly missing fall protection €307,017
On 21.01. and 10 March 2026, the U.S. Occupational Safety and Health Administration (OSHA) found at two residential construction sites in Rockledge that employees of the roofing contractor were working on roofs without fall protection; training records, eye protection when using nail guns and ladders extending sufficiently above the roof edge were also missing. The company had been inspected seven times since 2023, each time with fall protection violations. Proposed: $349,754 (2 wilful, 4 repeat violations).
Companies that allow the same fall hazards to recur after earlier inspections risk classification as a repeat or wilful violation with substantially higher penalties.
Fall protection during roofing work
Missing or inadequate training played a role in the decision.
- Authority / court
- U.S. Department of Labor – Occupational Safety and Health Administration (OSHA)
- Area of law
- Health and safety and employment law · Workplace safety and accidents
- Legal basis
- 29 CFR 1926 Subpart M (Fall Protection), Subpart X (Ladders)
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Construction and real estate
- Culpability
- intentional
- Repeat case
- yes
- Published
- 23 Jul 2026
Original amount 349,754 USD, converted at the ECB reference rate of 23 Jul 2026.
Checked against the official source on 25 Sep 2026 · Direct link
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20 Jul 2026 NeoGenomics Laboratories Inc.NeoGenomics: 9.8 million USD after self-disclosure – discounted consulting for referring physicians €8.59m
The Florida laboratory provided referring physicians with consulting services below market value and paid independent consultants referral-based remuneration for recruiting physicians. Following a self-disclosure, NeoGenomics paid 9,813,260 USD.
Free or discounted services are also benefits – like cash payments, they belong in the anti-corruption review.
Services with monetary value provided to customers below market value
- Authority / court
- U.S. Department of Justice
- Area of law
- Bribery and corruption · Commercial bribery
- Legal basis
- Anti-Kickback Statute (42 U.S.C. § 1320a-7b(b)); False Claims Act (31 U.S.C. §§ 3729 ff.)
- Action
- Other
- Status of proceedings
- final
- Sector
- Healthcare
- Mitigating circumstances
- Self-disclosure of the remuneration arrangements.
Original amount 9,813,260 USD, converted at the ECB reference rate of 20 Jul 2026.
- HHS-OIG Enforcement Actions: Florida Laboratory Agrees to Pay $9.8M … Self-Disclosure of Compensation Arrangements (20.07.2026) Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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20 Jul 2026 EyePoint Pharmaceuticals, Inc.EyePoint: 4.66 million USD – kickbacks to surgery centres for purchasing an eye medicine €4.08m
Between January 2019 and March 2023, the pharmaceutical manufacturer allegedly paid kickbacks to ambulatory surgery centres to induce them to purchase and use the injectable drug DEXYCU for cataract surgery. To resolve the False Claims Act allegations, EyePoint paid 4,657,463.18 USD and entered into a Corporate Integrity Agreement with HHS-OIG.
Discounts, payments or services to institutions that make purchasing decisions require a documented consideration at market value.
Granting benefits to customers and purchasing decision-makers
- Authority / court
- U.S. Department of Justice
- Area of law
- Bribery and corruption · Commercial bribery
- Legal basis
- Anti-Kickback Statute (42 U.S.C. § 1320a-7b(b)); False Claims Act (31 U.S.C. §§ 3729 ff.)
- Action
- Other
- Status of proceedings
- final
- Sector
- Chemicals and pharmaceuticals
Original amount 4,657,463.18 USD, converted at the ECB reference rate of 20 Jul 2026.
- HHS-OIG Enforcement Actions: EyePoint Pharmaceuticals to Pay $4.6 Million to Resolve False Claims Act Allegations (20.07.2026) Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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17 Jul 2026 The Scoular CompanyAgricultural trader Scoular pays 10 million USD over bribes to Mexican border officials €8.91m
From 2013 to 2019, Scoular had customs brokers pay around 400,000 USD to Mexican border and inspection officials so that trains carrying contaminated maize and grain would pass inspections; some of the money went to individuals close to cartels. Three-year DPA with a criminal penalty of 9,769,521 USD and forfeiture of 414,351 USD.
Customs agents and freight forwarders are high-risk third parties: question conspicuous flat fees per shipment, even if they appear to be customary charges.
Facilitation payments via customs agents and logistics service providers
Missing or inadequate training played a role in the decision.
- Authority / court
- U.S. Department of Justice (Criminal Division, Fraud Section; USAO Western District of Texas)
- Area of law
- Bribery and corruption · Bribery of public officials
- Legal basis
- FCPA (Verschwörung zur Verletzung der Anti-Bestechungsvorschriften); Deferred Prosecution Agreement
- Action
- Fine
- Status of proceedings
- final
- Sector
- Food and agriculture
- Culpability
- intentional
- Mitigating circumstances
- Cooperation and remediation (including an overhaul of compliance, third-party management, financial controls and anti-corruption training); 25 % reduction off the low end of the sentencing guidelines range.
- Liability of senior managers
- The customs broker Carlos Leopoldo Alvelais has pleaded guilty.
- Published
- 17 Jul 2026
Original amount 10,183,872 USD, converted at the ECB reference rate of 17 Jul 2026.
- Agricultural Company to Pay Over $10M to Resolve Foreign Bribery Case Press release of an authority
- Deferred Prosecution Agreement, United States v. The Scoular Company, 3:26-cr-01685-KC (W.D. Tex.), filed 07/17/26 Decision of an authority
- DOJ Criminal Division: United States v. The Scoular Company (Fallseite) Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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15 Jul 2026 Vanilla Chip LLC (TruHeight)TruHeight: FTC settlement over allegedly fake reviews for growth supplement €657,549
According to the FTC, employees of the dietary supplement provider wrote thousands of five-star reviews, customers received free products or discounts in return for five-star reviews, and bot profiles posed as real users; in addition, there were unsubstantiated growth claims for children and adolescents. The final settlement order provides for a judgment of 4 million USD, which is partially suspended on account of limited ability to pay after payment of 750,000 USD.
Reviews by employees or reviews rewarded for positive star ratings are prohibited and, since 2024, subject to civil penalties.
Fake and purchased customer reviews
- Authority / court
- Federal Trade Commission (FTC)
- Area of law
- Consumer protection and online retail · Fake reviews
- Legal basis
- Section 5 FTC Act; FTC Rule on the Use of Consumer Reviews and Testimonials
- Action
- Disgorgement of profits
- Status of proceedings
- final
- Sector
- Food and agriculture
- Mitigating circumstances
- Partial suspension of the judgment on account of limited ability to pay.
- Liability of senior managers
- The co-founders and co-CEOs Eden Stelmach and Justin Rapoport are personally parties to the order.
- Published
- 15 Jul 2026
Original amount 750,000 USD, converted at the ECB reference rate of 15 Jul 2026.
- FTC Takes Action Against TruHeight for Deceptive, Unsubstantiated Advertising Press release of an authority
- FTC Approves Final Order Against TruHeight (15.07.2026) Press release of an authority
- FTC Case: TruHeight (Vanilla Chip LLC), Docket C-4837, Final Decision and Order Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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15 Jul 2026 FleetPride Inc.FleetPride: $264,380 after asphyxiation death during tank trailer inspection €231,790
At the truck parts distributor's Corpus Christi (Texas) site, an employee was asphyxiated while inspecting a tank trailer. The U.S. Occupational Safety and Health Administration (OSHA) found no confined space programme, deficiencies in the respiratory protection programme and electrical hazards, and proposed $264,380 (16 serious, 3 other violations).
Tanks and vessels are confined spaces with a risk of asphyxiation – no one may enter without a permit, atmospheric testing and an attendant.
Working in confined spaces and vessels
- Authority / court
- U.S. Department of Labor – Occupational Safety and Health Administration (OSHA)
- Area of law
- Health and safety and employment law · Workplace safety and accidents
- Legal basis
- 29 CFR 1910.146 (Permit-required confined spaces); 29 CFR 1910.134 (Respiratory protection)
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Retail and e-commerce
- Published
- 15 Jul 2026
Original amount 264,380 USD, converted at the ECB reference rate of 15 Jul 2026.
- US Department of Labor cites big rig parts distributer for confined space, safety hazards after worker fatality (OSHA) Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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23 Jun 2026 Needle Craft Ltd.; Casual Wear Apparel LLCCBP import stop for textiles from Jordan's Needle Craft and Casual Wear Apparel Order
U.S. Customs and Border Protection (CBP) issued a Withhold Release Order: clothing from Needle Craft Ltd.; Casual Wear Apparel LLC (Jordan) is being detained at all US ports of entry because there are indications of forced labour (ILO indicators including physical and sexual violence, retention of identity documents, restriction of movement and withholding of wages). These are two parallel orders against both manufacturers.
Fashion brands should supplement social audits at garment makers with confidential worker interviews, because violence and confiscation of identity documents remain invisible in paper-based checks.
- Authority / court
- U.S. Customs and Border Protection
- Area of law
- Supply chain and human rights · Forced and child labour
- Legal basis
- 19 U.S.C. § 1307 (Tariff Act of 1930, Section 307)
- Action
- Order
- Status of proceedings
- unknown
- Sector
- Other
- Published
- 23 Jun 2026
- CBP issues 2 Withhold Release Orders on Needle Craft and Casual Wear Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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18 Jun 2026 LOGZONE Inc.LOGZONE pays 507,144 USD over lack of cybersecurity in Navy contracts €442,495
The Huntsville-based defence services provider allegedly invoiced two Navy contracts from May 2021 to March 2025 even though it had not implemented the security controls under NIST SP 800-171 required by the contracts. The settlement under the False Claims Act with the U.S. Department of Justice amounts to 507,144 USD.
Companies that commit to cybersecurity requirements in government contracts must document their implementation verifiably – otherwise every invoice becomes a liability risk.
- Authority / court
- U.S. Department of Justice (Civil Division) / USAO Northern District of Alabama
- Area of law
- Other
- Legal basis
- False Claims Act (31 U.S.C. §§ 3729 ff.); DFARS-Cybersicherheitsklauseln
- Action
- Other
- Status of proceedings
- final
- Sector
- Defence and security
- Published
- 18 Jun 2026
Original amount 507,144 USD, converted at the ECB reference rate of 18 Jun 2026.
Checked against the official source on 25 Sep 2026 · Direct link
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17 Jun 2026 Advanced Pathology Solutions PLLC und APS MSO LLCAdvanced Pathology Solutions: 30 million USD for kickbacks and unnecessary laboratory tests €25.9m
The Arkansas pathology laboratory, its management company and the owners Kevin Hannah, Donell Burkett and Daniel Hunter Pledger allegedly granted unlawful kickbacks and ordered medically unnecessary tests. Together they paid 30 million USD; the laboratory entered into a Corporate Integrity Agreement.
Where services are sold through referrals, all benefits to referrers belong in a central approval and review procedure.
Benefits to clients in healthcare
- Authority / court
- U.S. Department of Justice
- Area of law
- Bribery and corruption · Commercial bribery
- Legal basis
- Anti-Kickback Statute (42 U.S.C. § 1320a-7b(b)); False Claims Act (31 U.S.C. §§ 3729 ff.)
- Action
- Other
- Status of proceedings
- final
- Sector
- Healthcare
- Liability of senior managers
- The owners contribute personally as parties to the settlement.
Original amount 30,000,000 USD, converted at the ECB reference rate of 17 Jun 2026.
- HHS-OIG Enforcement Actions: Arkansas Pathology Laboratory and Its Owners Pay $30M … (17.06.2026) Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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16 Jun 2026 Robert Bosch GmbHBosch pays 36 million USD for sensor supplies to Huawei €31.2m
Between September 2020 and September 2024, Bosch exported MEMS sensors and vehicle software worth around 72.4 million USD from outside the US without a licence to Huawei and affiliated companies on the Entity List (Foreign Direct Product Rule). Bosch voluntarily disclosed the violations; around 3.6 million USD of the penalty imposed by the US Commerce Department's Bureau of Industry and Security (BIS) is credited against a disgorgement agreed with the DOJ.
Even products manufactured outside the US can be subject to US export controls via US technology – supplies to Entity List customers need their own review.
US export law for foreign-made products (Foreign Direct Product Rule)
- Authority / court
- U.S. Department of Commerce, Bureau of Industry and Security (BIS)
- Area of law
- Sanctions and export control · Export control and dual-use goods
- Legal basis
- Export Administration Regulations (Foreign Direct Product Rule, Entity List)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Automotive
- Employees
- 10,000 or more
- Mitigating circumstances
- Voluntary self-disclosure and cooperation
- Published
- 17 Jun 2026
Original amount 36,184,680 USD, converted at the ECB reference rate of 16 Jun 2026.
- BIS: Robert Bosch GmbH (Bosch) to Pay $36 Million Penalty for BIS Violations Pertaining to Shipments to Huawei (17.06.2026) Press release of an authority
- BIS Order Relating to Robert Bosch GmbH (16.06.2026) Decision of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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16 Jun 2026 Serbia Zijin Copper D.O.O.CBP import stop for copper from Serbia Zijin Copper over forced labour indicators Order
U.S. Customs and Border Protection (CBP) issued a Withhold Release Order: copper and copper products from Serbia Zijin Copper D.O.O. (Serbia) are being detained at all US ports of entry because there are indications of forced labour (ILO indicators including withholding of wages, intimidation, restriction of movement and retention of identity documents).
Production in Europe is no free pass either: raw material and metal supply chains need their own forced labour checks.
- Authority / court
- U.S. Customs and Border Protection
- Area of law
- Supply chain and human rights · Forced and child labour
- Legal basis
- 19 U.S.C. § 1307 (Tariff Act of 1930, Section 307)
- Action
- Order
- Status of proceedings
- unknown
- Sector
- Steel and metals
- Published
- 16 Jun 2026
- CBP issues Withhold Release Order on Serbia Zijin Copper D.O.O. Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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5 Jun 2026 Illuminate Education Inc.FTC: final order against education software provider Illuminate after data leak affecting 10.1 million students Order
According to the complaint by the US Federal Trade Commission (FTC), Illuminate promised schools data security but did not adequately protect its cloud databases, even though a service provider had pointed out vulnerabilities almost two years earlier; a hacker accessed data on 10.1 million students, including health information. The order requires an information security programme, data minimisation and a public deletion schedule, and prohibits misrepresentations about security and notification deadlines.
Do not leave known vulnerabilities unaddressed for years – security promises to customers are measured as binding commitments.
- Authority / court
- Federal Trade Commission (FTC)
- Area of law
- Data protection · Data breaches and data security
- Legal basis
- FTC Act (Verbot unlauterer und irreführender Praktiken)
- Action
- Order
- Status of proceedings
- final
- Sector
- Telecoms, IT and software
- Culpability
- negligent
- Published
- 5 Jun 2026
- FTC Gives Final Approval to Order Against Illuminate Settling Allegations It Failed to Secure Students' Personal Data Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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2 Jun 2026 Ascension Health Alliance; AmSurg LLC / Ambulatory Topco LLCAscension/AmSurg: seven ambulatory surgery centres must be sold Order
The non-profit hospital group Ascension wanted to acquire AmSurg for 3.9 billion USD. Owing to overlaps in outpatient surgery in five regions, the Federal Trade Commission (FTC) requires the sale of seven AmSurg centres to SC Affiliates and a gastroenterology practice, as well as transitional support.
Non-profit healthcare providers are also subject to merger control – regional market shares determine divestitures.
- Authority / court
- Federal Trade Commission (FTC)
- Area of law
- Competition law · Merger control
- Legal basis
- Section 7 Clayton Act; Section 5 FTC Act (Consent Order)
- Action
- Order
- Status of proceedings
- unknown
- Sector
- Healthcare
- Employees
- 10,000 or more
- FTC Requires Divestiture of Ambulatory Surgery Centers … Ascension Health-AmSurg Deal (02.06.2026) Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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22 May 2026 Foot Locker, Inc.SEC: Foot Locker pays 148,000 US dollars over award waivers in separation agreements €127,641
From July 2020 to June 2024, around 148 departing employees – including managers and staff from finance, legal and supply chain – signed separation agreements containing a waiver of SEC whistleblower awards. Foot Locker had itself phased out the clause from March 2024 but had not amended all templates; the U.S. Securities and Exchange Commission (SEC) imposed 148,000 US dollars.
When cleaning up clauses, all contract templates must be covered – a single forgotten template is enough for a violation.
Whistleblower protection in contract templates (HR/Legal)
- Authority / court
- U.S. Securities and Exchange Commission
- Area of law
- Whistleblower protection · Retaliation against whistleblowers
- Legal basis
- Securities Exchange Act of 1934, Rule 21F-17(a)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Retail and e-commerce
- Employees
- 10,000 or more
- Mitigating circumstances
- Clause phased out before contact by the SEC; cooperation and prompt remediation
- Published
- 22 May 2026
Original amount 148,000 USD, converted at the ECB reference rate of 22 May 2026.
- In the Matter of Foot Locker, Inc., Release No. 34-105542 Decision of an authority
- SEC Whistleblower Protections – Enforcement Actions Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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18 May 2026 Adani Enterprises LimitedAdani Enterprises pays 275 million USD over Iranian liquefied petroleum gas €236.1m
From November 2023 to June 2025, the Indian conglomerate bought allegedly Omani and Iraqi liquefied petroleum gas (LPG) via a trader in Dubai which in fact originated from Iran; 32 payments totalling around 192 million USD were routed through US banks. The US Treasury's Office of Foreign Assets Control (OFAC) assessed the violations as egregious and not voluntarily self-disclosed; Adani had recklessly ignored numerous warning signs (AIS manipulation by the tankers, implausible loading ports, conspicuous price discounts, irregularities in the certificates of origin).
Companies that source commodities below market price via intermediaries must actively check origin, vessel movements and documents – mere name screening against sanctions lists is not enough.
Warning signs in commodity and shipping transactions (origin, AIS gaps, price discounts)
- Authority / court
- U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC)
- Area of law
- Sanctions and export control · Breaches of sanctions and embargoes
- Legal basis
- Iranian Transactions and Sanctions Regulations (31 C.F.R. part 560); IEEPA
- Action
- Fine
- Status of proceedings
- final
- Sector
- Energy and utilities
- Mitigating circumstances
- Remedial measures after discovery and cooperation with OFAC
- Published
- 18 May 2026
Original amount 275,000,000 USD, converted at the ECB reference rate of 18 May 2026.
- OFAC Enforcement Release: Adani Enterprises Limited Settles with OFAC for $275,000,000 (18.05.2026) Decision of an authority
- OFAC – Civil Penalties and Enforcement Information Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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18 May 2026 Volvo Group North America, LLCVolvo Group North America: settlement of around 197 million USD over undisclosed emission control devices €168.7m
Around 10,000 heavy-duty Volvo diesel engines from model years 2010 to 2016 used auxiliary emission control devices (AECDs) that were not disclosed during certification and emitted more NOx than permitted. The settlement with the California Air Resources Board (CARB) comprises 17.5 million USD in penalties and costs, 71 million USD for mitigation measures and 108 million USD for emission reduction projects in California.
Every emissions-relevant control function must be fully disclosed in the certification application; otherwise high settlement payments may follow years later.
- Authority / court
- California Air Resources Board (CARB)
- Area of law
- Environment and sustainability · Emissions and permits
- Legal basis
- Kalifornische Emissions- und Zertifizierungsvorschriften für schwere Nutzfahrzeugmotoren
- Action
- Fine
- Status of proceedings
- final
- Sector
- Automotive
- Employees
- 10,000 or more
- Mitigating circumstances
- Cooperation during the investigation; recall and extended warranty for engines from model years 2014 to 2016.
- Published
- 18 May 2026
Original amount 196,500,000 USD, converted at the ECB reference rate of 18 May 2026.
Checked against the official source on 25 Sep 2026 · Direct link
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14 May 2026 Takeda Pharmaceuticals U.S.A., Inc.Takeda: 13.7 million USD – speaker fees and luxury meals for prescribing physicians €11.7m
From 2014 to 2020, Takeda allegedly selected physicians specifically for its speaker programme for the antidepressant Trintellix and provided them with fees and meals at expensive restaurants to promote prescriptions; some participants attended the same event several times without any educational benefit. Takeda paid 13,670,921 USD.
Speaker programmes need a demonstrable educational purpose – repeated attendance and expensive hospitality turn them into inducements.
Invitations, hospitality and fees for healthcare professionals
- Authority / court
- U.S. Department of Justice / U.S. Attorney's Office, Eastern District of California
- Area of law
- Bribery and corruption · Gifts, hospitality and benefits
- Legal basis
- Anti-Kickback Statute (42 U.S.C. § 1320a-7b(b)); False Claims Act (31 U.S.C. §§ 3729 ff.)
- Action
- Other
- Status of proceedings
- final
- Sector
- Chemicals and pharmaceuticals
- Employees
- 10,000 or more
Original amount 13,670,921 USD, converted at the ECB reference rate of 14 May 2026.
- DOJ: Takeda Agrees to Pay $13.6M to Resolve False Claims Allegations Relating to Improper Payments (14.05.2026) Press release of an authority
- HHS-OIG Enforcement Actions: Takeda Agrees to Pay $13.6M … Improper Payments to Physicians (14.05.2026) Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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1 May 2026 Modern Nuclear Inc.Modern Nuclear: 8.33 million USD – excessive supervision fees paid to referring cardiologists €7.12m
The Californian provider of mobile PET scans allegedly paid referring cardiologists excessive fees for supervising the examinations in order to secure referrals. The settlement of 8,334,350.71 USD plus revenue-based payments is based on ability to pay; in addition, there is a Corporate Integrity Agreement.
Remuneration of business partners who refer work must correspond to the market value of the service – any overpayment acts as a bribe.
Checking fee agreements with referrers for market conformity
- Authority / court
- U.S. Department of Justice / U.S. Attorney's Office, Central District of California
- Area of law
- Bribery and corruption · Commercial bribery
- Legal basis
- Anti-Kickback Statute (42 U.S.C. § 1320a-7b(b)); False Claims Act (31 U.S.C. §§ 3729 ff.)
- Action
- Other
- Status of proceedings
- final
- Sector
- Healthcare
Original amount 8,334,350.71 USD, converted at the ECB reference rate of 30 Apr 2026.
- HHS-OIG Enforcement Actions: Mobile PET Scan Provider to Pay $8.33 Million … Unlawful Kickbacks to Medical Practices (01.05.2026) Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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29 Apr 2026 Delta Dental Insurance Company und Delta Dental of New York, Inc.NYDFS: $2.25 million against Delta Dental after MOVEit attack and late notification €1.92m
In 2023, attackers exploited a zero-day vulnerability in MOVEit Transfer to steal files containing social security, driving licence, account and health data. The New York State Department of Financial Services (NYDFS) criticised inadequate retention settings, policies and controls as well as the late notification of the cybersecurity incidents to the supervisory authority.
Keep data in transfer tools only for as long as necessary – and report security incidents to the supervisory authority on time.
- Authority / court
- New York State Department of Financial Services (NYDFS)
- Area of law
- Information security and cyber · Security measures and risk management
- Legal basis
- 23 NYCRR Part 500 (Cybersecurity Regulation)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Financial services and insurance
- Culpability
- negligent
- Published
- 30 Apr 2026
Original amount 2,250,000 USD, converted at the ECB reference rate of 29 Apr 2026.
- DFS Secures $2.25 Million Cybersecurity Settlement with Delta Dental Press release of an authority
- Consent Order to Delta Dental 2026 Decision of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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28 Apr 2026 Purdue Pharma L.P.Purdue Pharma: 5.544 billion USD penalty – including kickbacks via the speaker programme €4.75bn
Following its 2020 guilty plea, the opioid manufacturer was sentenced in Newark to a criminal fine of 3.544 billion USD (asserted in the insolvency proceedings) and forfeiture of 2 billion USD; up to 1.775 billion USD can be credited against the forfeiture if Purdue emerges from insolvency as a public benefit company. Purdue had deceived the DEA and paid kickbacks to prescribers via its speaker programme and to an electronic health records platform in order to increase opioid prescriptions.
Fee programmes for customers who drive revenue can become part of a criminal overall scheme – with consequences that threaten the company’s existence.
Speaker fees and benefits for prescribing physicians
- Authority / court
- U.S. District Court, District of New Jersey (Anklage: U.S. Department of Justice)
- Area of law
- Bribery and corruption · Gifts, hospitality and benefits
- Legal basis
- Verschwörung zum Betrug der USA und zur Verletzung des Food, Drug, and Cosmetic Act; zwei Fälle Verschwörung zur Verletzung des Anti-Kickback Statute (Schuldbekenntnis vom 24.11.2020)
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Chemicals and pharmaceuticals
- Culpability
- intentional
Original amount 5,544,000,000 USD, converted at the ECB reference rate of 28 Apr 2026.
- HHS-OIG Enforcement Actions: Opioid Manufacturer Purdue Pharma Sentenced for Fraud and Kickback Conspiracies (28.04.2026) Enforcement database of an authority
- U.S. Department of Justice: Opioid Manufacturer Purdue Pharma Sentenced for Fraud and Kickback Conspiracies (28.04.2026) Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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17 Mar 2026 W International LLC; W International SC LLC; Precision Metal Equipment Handling LLCW International pays 10.5 million USD for overpriced welding tables for Air Force and Navy €9.11m
The metal fabrication companies and their CEO Edward Walker allegedly knowingly overcharged the Air Force and the Navy for welding tables for the modernisation of a large welding facility; the project was financed in part with funds under the Defense Production Act. The settlement under the False Claims Act amounts to 10.5 million USD; a former employee received 1,863,750 USD as a whistleblower.
Price information provided to public contracting authorities must be calculated on a sound basis; internal whistleblowers regularly bring such cases to the authorities.
- Authority / court
- U.S. Department of Justice (Civil Division) / USAO District of South Carolina
- Area of law
- Other
- Legal basis
- False Claims Act (31 U.S.C. §§ 3729 ff.)
- Action
- Other
- Status of proceedings
- final
- Sector
- Steel and metals
- Liability of senior managers
- CEO Edward Walker is personally a party to the settlement.
- Published
- 17 Mar 2026
Original amount 10,500,000 USD, converted at the ECB reference rate of 17 Mar 2026.
Checked against the official source on 25 Sep 2026 · Direct link
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17 Mar 2026 Balt SAS / Balt USA LLCMedical technology: DOJ declination for Balt SAS after bribery of a hospital physician €1.05m
Through sham consultancy agreements, fictitious invoices and purported bonus payments, around 602,000 USD in bribes flowed from 2017 to 2023 via a Belgian consultant to a physician in a senior position at a French public hospital, so that the hospital would purchase embolisation coils from Balt. The DOJ declined to prosecute on account of voluntary self-disclosure, cooperation and remediation (declination of 17 March 2026); Balt is disgorging 1,214,797 USD in profits.
Physicians at public hospitals are public officials – consultancy agreements with them require documented services and approval by the compliance function.
Benefits to physicians in the public healthcare sector, sham consultancy agreements
- Authority / court
- U.S. Department of Justice (Criminal Division, Fraud Section)
- Area of law
- Bribery and corruption · Bribery of public officials
- Legal basis
- FCPA; Corporate Enforcement and Voluntary Self-Disclosure Policy (Declination)
- Action
- Disgorgement of profits
- Status of proceedings
- final
- Sector
- Healthcare
- Culpability
- intentional
- Mitigating circumstances
- Voluntary self-disclosure (including to the French national financial prosecutor's office, PNF), full cooperation, timely remediation, disciplinary measures, parallel resolution in France.
- Liability of senior managers
- A former manager of the US subsidiary (David Ferrera) and a consultant (Marc Tilman) were charged with FCPA violations and money laundering.
- Published
- 19 Mar 2026
Original amount 1,214,797 USD, converted at the ECB reference rate of 17 Mar 2026.
- Justice Department Resolves Foreign Bribery Investigation with Balt SAS; Healthcare Executive and Sales Consultant Indicted Press release of an authority
- Communiqué de presse du procureur de la République financier – CJIP BALT USA (19.03.2026) Press release of an authority
- DOJ Criminal Division, Fraud Section: Declination Letter Re: Balt SAS (17.03.2026) Decision of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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6 Mar 2026 Canaccord Genuity LLCFinCEN: 80 million USD against Canaccord Genuity over AML and correspondent banking deficiencies €69.2m
The US Financial Crimes Enforcement Network (FinCEN) imposed 80 million USD on the broker-dealer, which admitted wilful BSA infringements: no effective AML programme, no due diligence on correspondent accounts of foreign financial institutions and failure to file suspicious activity reports in connection with securities fraud. Remedial measures that had been promised were not implemented for years.
Implement remedial measures promised in writing to the supervisory authority genuinely and swiftly – years of delay aggravate the later sanction.
- Authority / court
- Financial Crimes Enforcement Network (FinCEN)
- Area of law
- Money laundering and terrorist financing · Customer due diligence
- Legal basis
- Bank Secrecy Act (BSA)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Financial services and insurance
- Culpability
- intentional
- Published
- 6 Mar 2026
Original amount 80,000,000 USD, converted at the ECB reference rate of 6 Mar 2026.
Checked against the official source on 25 Sep 2026 · Direct link
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5 Mar 2026 Allin IP DX LLCAllin IP DX: 980,000 USD after self-disclosure over paid referral marketers €843,519
Between January and June 2023, the Sarasota laboratory paid independent marketers to steer laboratory samples from Medicare beneficiaries to it. It self-disclosed the conduct, cooperated extensively and paid 980,000 USD.
Early self-disclosure limits the damage – but this requires the compliance function to actually get to see problematic sales contracts.
Success-based remuneration of sales partners
- Authority / court
- U.S. Attorney's Office, Middle District of Florida
- Area of law
- Bribery and corruption · Commercial bribery
- Legal basis
- Anti-Kickback Statute (42 U.S.C. § 1320a-7b(b)); False Claims Act (31 U.S.C. §§ 3729 ff.)
- Action
- Other
- Status of proceedings
- final
- Sector
- Healthcare
- Mitigating circumstances
- Voluntary self-disclosure, detailed disclosure and cooperation.
Original amount 980,000 USD, converted at the ECB reference rate of 5 Mar 2026.
- HHS-OIG Enforcement Actions: Sarasota Lab Agrees to Pay $980,000 to Resolve False Claims Act Violations (05.03.2026) Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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26 Feb 2026 Teledyne FLIR LLCTeledyne FLIR: thermal imaging cameras incorrectly assessed and supplied to Entity List address €846,453
The manufacturer of militarily relevant thermal imaging technology admitted 19 violations to the US Commerce Department's Bureau of Industry and Security (BIS): incorrect de minimis calculations for cameras that went to China via Sweden, pricing arranged with a Chinese drone manufacturer to circumvent the licence requirement, missing records and eight deliveries in 2024 to a Hong Kong address on the Entity List that the screening software did not detect.
Actively incorporate new forms of listing, such as address-only entries, into screening; do not rely solely on the software provider.
De minimis calculation, address-based Entity List entries in screening
- Authority / court
- U.S. Department of Commerce, Bureau of Industry and Security (BIS)
- Area of law
- Sanctions and export control · Export control and dual-use goods
- Legal basis
- Export Administration Regulations, §§ 734.4 (De minimis), 744.16, 764.2(a), (b), (h), (i)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Defence and security
- Mitigating circumstances
- Voluntary self-disclosures for some of the violations
- Published
- 26 Feb 2026
Original amount 1,000,000 USD, converted at the ECB reference rate of 26 Feb 2026.
- BIS Reaches Administrative Enforcement Settlement with Teledyne FLIR LLC and its affiliates (26.02.2026) Press release of an authority
- BIS Order Relating to Teledyne FLIR LLC (26.02.2026) Decision of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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26 Feb 2026 All FAB Precision Sheetmetal, Inc.Sheet metal fabricator: second amputation on the same press brake – Cal/OSHA $212,850 €180,168
In June 2025, an employee in San Jose lost a finger on a press brake without guarding – identical to an accident in June 2024 for which the business had already been fined $43,500. The California Division of Occupational Safety and Health (Cal/OSHA) imposed $212,850 (including a wilful repeat violation); the employer appealed.
After an accident, retrofitting the machine is mandatory – an identical second accident will be treated as wilful.
- Authority / court
- California Division of Occupational Safety and Health (Cal/OSHA)
- Area of law
- Health and safety and employment law · Workplace safety and accidents
- Legal basis
- California Code of Regulations, Title 8 (Maschinenschutz)
- Action
- Fine
- Status of proceedings
- under appeal
- Sector
- Steel and metals
- Culpability
- intentional
- Repeat case
- yes
- Published
- 26 Feb 2026
Original amount 212,850 USD, converted at the ECB reference rate of 26 Feb 2026.
- Cal/OSHA cites San Jose sheet metal company more than $212,000 following amputation accident (DIR) Press release of an authority
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11 Feb 2026 Applied Materials, Inc. und Applied Materials Korea, Ltd.Applied Materials pays 252 million USD for chip equipment exports to China €212.2m
In 2021 and 2022, Applied Materials and its Korean subsidiary exported ion implanters for semiconductor manufacturing worth around 126 million USD via Korea without a licence to a Chinese company placed on the Entity List in 2020. The penalty imposed by the US Commerce Department's Bureau of Industry and Security (BIS) corresponds to twice the transaction value and thus the statutory maximum; the compliance staff and executives responsible are no longer with the company.
Routing through foreign subsidiaries does not remove the licence requirement; export control needs audits and clear accountability of management.
Entity List screening for deliveries via subsidiaries
- Authority / court
- U.S. Department of Commerce, Bureau of Industry and Security (BIS)
- Area of law
- Sanctions and export control · Export control and dual-use goods
- Legal basis
- Export Administration Regulations (Entity List)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Manufacturing and mechanical engineering
- Employees
- 10,000 or more
- Liability of senior managers
- According to BIS, the responsible compliance staff and senior executives from sales and production are no longer employed.
- Published
- 12 Feb 2026
Original amount 252,500,300 USD, converted at the ECB reference rate of 11 Feb 2026.
- BIS: Applied Materials to Pay $252 Million Penalty for Illegally Exporting Semiconductor Manufacturing Equipment (12.02.2026) Press release of an authority
- BIS Order Relating to Applied Materials, Inc. and Applied Materials Korea (11.02.2026) Decision of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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11 Feb 2026 Disney DTC, LLC und ABC Enterprises, Inc. (The Walt Disney Company)California: $2.75 million against Disney over incomplete opt-outs for streaming €2.31m
Disney implemented objections to the sale and sharing of data only for individual services or devices rather than across the whole account, continued to disclose data via embedded ad-tech providers and offered no opt-out in connected TV apps. It was the largest CCPA settlement at the time of the agreement with the Attorney General of California.
An opt-out must take effect across all services, devices and integrated third-party providers of an account.
- Authority / court
- Attorney General of California (California Department of Justice)
- Area of law
- Data protection · Cookies and tracking
- Legal basis
- California Consumer Privacy Act (CCPA)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Media and online platforms
- Employees
- 10,000 or more
- Published
- 11 Feb 2026
Original amount 2,750,000 USD, converted at the ECB reference rate of 11 Feb 2026.
Checked against the official source on 25 Sep 2026 · Direct link
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10 Feb 2026 Paxful Holdings Inc.Crypto platform Paxful: 4 million USD penalty after guilty plea to BSA infringements €3.36m
Following a guilty plea to charges including conspiracy to operate an unlicensed money transmitting business and to violate the AML obligations of the Bank Secrecy Act, the peer-to-peer crypto platform was sentenced to a penalty of 4 million USD. 112.5 million USD would have been appropriate, but the US Department of Justice (DOJ) found an inability to pay; in December 2025, FinCEN had additionally imposed a civil penalty of 3.5 million USD.
Crypto platforms without registration and KYC face criminal liability – up to the limit of their ability to pay.
- Authority / court
- U.S. Department of Justice
- Area of law
- Money laundering and terrorist financing · Internal controls
- Legal basis
- Travel Act; Verschwörung zum Betrieb eines nicht lizenzierten Geldtransfergeschäfts und zur Verletzung der AML-Pflichten des Bank Secrecy Act
- Action
- Fine
- Status of proceedings
- final
- Sector
- Financial services and insurance
- Culpability
- intentional
- Mitigating circumstances
- Penalty limited from 112.5 million to 4 million USD because of proven inability to pay
- Published
- 11 Feb 2026
Original amount 4,000,000 USD, converted at the ECB reference rate of 10 Feb 2026.
- Virtual Asset Trading Platform Sentenced for Violating the Travel Act and Other Federal Criminal Charges Press release of an authority
- FinCEN Assesses $3.5 Million Penalty Against Paxful for Facilitating Suspicious Activity Involving Illicit Actors Press release of an authority
- FinCEN Consent Order Imposing Civil Money Penalty – Paxful, Inc. and Paxful USA, Inc. (Number 2025-02) Decision of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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4 Feb 2026 Alco Harvesting LLC dba Bonipak Produce Inc. und verbundene UnternehmenBonipak: $6.175 million for farmworkers over undisclosed paid sick leave €5.22m
Following the COVID death of a farmworker in employer-provided housing, the California Labor Commissioner's Office sued the agricultural business in Santa Maria in 2021: more than 10,000 farmworkers, including H-2A seasonal workers, had not been informed of their entitlement to paid sick leave; in addition, there was unpaid travel time as well as overtime and minimum wage violations. The settlement of $6,175,000 (of which $4.2 million goes directly to workers) includes posting and reporting obligations.
Information obligations towards seasonal workers are not a formality – companies that leave workers in the dark about paid sick leave are liable for the consequences.
- Authority / court
- California Labor Commissioner's Office (Division of Labor Standards Enforcement)
- Area of law
- Health and safety and employment law · Minimum wage and undeclared work
- Legal basis
- California Labor Code (Paid Sick Leave, COVID-19 Supplemental Paid Sick Leave, Mindestlohn, Überstunden)
- Action
- Other
- Status of proceedings
- final
- Sector
- Food and agriculture
- Published
- 4 Feb 2026
Original amount 6,175,000 USD, converted at the ECB reference rate of 4 Feb 2026.
Checked against the official source on 25 Sep 2026 · Direct link
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29 Jan 2026 Finca Monte GrandeCBP stops coffee from Mexican Finca Monte Grande over forced labour Order
U.S. Customs and Border Protection (CBP) issued a Withhold Release Order: coffee from Finca Monte Grande (Mexico) is being detained at all US ports of entry because there are indications of forced labour (ILO indicators including debt bondage, withholding of wages, retention of identity documents and excessive overtime).
Importers of agricultural commodities should be able to check working conditions down to plantation level; otherwise they face detention at the border.
- Authority / court
- U.S. Customs and Border Protection
- Area of law
- Supply chain and human rights · Forced and child labour
- Legal basis
- 19 U.S.C. § 1307 (Tariff Act of 1930, Section 307)
- Action
- Order
- Status of proceedings
- unknown
- Sector
- Food and agriculture
- Published
- 29 Jan 2026
- CBP issues WRO against Finca Monte Grande Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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27 Jan 2026 Archer-Daniels-Midland Company (ADM)ADM: embellished segment results in Nutrition – 40 million USD penalty €34.5m
ADM and former executives had artificially inflated the results of the Nutrition segment through retroactive intra-group rebates and price adjustments in order to show growth targets of 15–20 %. ADM is paying a civil penalty of 40 million USD; two former managers are paying a combined 979,953 USD in disgorgement including interest and 200,000 USD in penalties, while litigation continues against a third.
Intra-group transfer prices and retroactive segment adjustments require independent control when segments are publicly promoted as growth drivers.
- Authority / court
- U.S. Securities and Exchange Commission (SEC)
- Area of law
- Capital markets and financial supervision · Disclosure and reporting obligations
- Legal basis
- Antifraud-, Reporting-, Buchführungs- und interne Kontrollvorschriften der US-Bundeswertpapiergesetze (Settled Order der SEC)
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Food and agriculture
- Mitigating circumstances
- ADM's cooperation and remedial measures were taken into account
- Liability of senior managers
- Vince Macciocchi: 404,343 USD disgorgement/interest, 125,000 USD penalty, 3-year officer-and-director bar; Ray Young: 575,610 USD disgorgement/interest, 75,000 USD penalty; action against Vikram Luthar pending
Original amount 41,179,953 USD, converted at the ECB reference rate of 27 Jan 2026.
- SEC Charges ADM and Three Former Executives with Accounting and Disclosure Fraud Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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13 Jan 2026 Maplebear Inc. (Instacart)Instacart pays 60 million USD in FTC settlement over "free delivery" with mandatory fees €51.5m
According to the FTC, Instacart advertised free delivery but charged mandatory service fees of up to 15 %, promised a "100 % satisfaction guarantee" without providing full refunds and did not sufficiently point out the subsequent charges for trial subscriptions. Under the settlement, the company is paying 60 million USD for refunds and must discontinue the practices complained of.
Anyone advertising something as "free" must not add a mandatory fee elsewhere.
Price advertising and disclosure of fees in marketing
- Authority / court
- Federal Trade Commission (FTC)
- Area of law
- Consumer protection and online retail · Misleading advertising and pricing
- Legal basis
- Section 5 FTC Act; Restore Online Shoppers' Confidence Act (ROSCA)
- Action
- Disgorgement of profits
- Status of proceedings
- final
- Sector
- Retail and e-commerce
- Published
- 18 Dec 2025
Original amount 60,000,000 USD, converted at the ECB reference rate of 13 Jan 2026.
- Instacart to Pay $60 Million in Consumer Refunds to Settle FTC Lawsuit Press release of an authority
- FTC v. Maplebear Inc. d/b/a Instacart – Stipulated Order (N.D. Cal., dated 13.01.2026) Court decision
Checked against the official source on 25 Sep 2026 · Direct link
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30 Dec 2025 Rickenbacher Data LLC (Datamasters)CPPA: $45,000 against data broker Datamasters over failure to register €38,275
Without registering as a data broker, the Texas reseller traded in the names and contact details of millions of people, sorted by illnesses such as Alzheimer's or addiction, by age, presumed ethnicity and political views. In addition to the fine, the California Privacy Protection Agency (CPPA) requires it to stop selling data on all Californians.
Companies that buy or sell address lists for advertising must check registration obligations – health-related lists are particularly risky.
- Authority / court
- California Privacy Protection Agency (CPPA)
- Area of law
- Data protection · Marketing and consent
- Legal basis
- California Delete Act (Registrierungspflicht für Datenhändler)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Other
- Published
- 8 Jan 2026
Original amount 45,000 USD, converted at the ECB reference rate of 30 Dec 2025.
- CalPrivacy Data Broker Enforcement Strike Force: enforcement actions Press release of an authority
- CPPA Order of Decision: Rickenbacher Data LLC d/b/a Datamasters (ENF25-172-D-DA) Decision of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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22 Dec 2025 New York-Presbyterian Hudson Valley HospitalNYP Hudson Valley Hospital: 6.8 million USD for payments to referring practice €5.79m
The hospital (until 2015 Hudson Valley Hospital Center) allegedly paid an oncology practice in Westchester millions of dollars to induce it to refer patients to the hospital; the hospital billed the services to Medicare and Medicaid. The U.S. Attorney’s Office filed a complaint and at the same time concluded a settlement of 6.8 million USD.
Cooperation agreements between hospitals and office-based practices must properly document services and remuneration – otherwise payments are treated as referral bonuses.
Payments to referrers in hospitals
- Authority / court
- U.S. Attorney's Office, Southern District of New York
- Area of law
- Bribery and corruption · Commercial bribery
- Legal basis
- Anti-Kickback Statute (42 U.S.C. § 1320a-7b(b)); False Claims Act (31 U.S.C. §§ 3729 ff.)
- Action
- Other
- Status of proceedings
- final
- Sector
- Healthcare
Original amount 6,800,000 USD, converted at the ECB reference rate of 22 Dec 2025.
- HHS-OIG Enforcement Actions: U.S. Attorney Announces $6.8 Million Settlement With New York-Presbyterian Hudson Valley Hospital … (22.12.2025) Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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18 Dec 2025 Linglong International Europe D.O.O. ZrenjaninCBP import stop for tyres from Linglong's plant in Serbia Order
U.S. Customs and Border Protection (CBP) issued a Withhold Release Order: car tyres from Linglong International Europe D.O.O. Zrenjanin (Serbia) are being detained at all US ports of entry because there are indications of forced labour (ILO indicators including deception, debt bondage, isolation, retention of identity documents and withholding of wages (nine indicators in total)).
Automotive suppliers should specifically audit recruitment, accommodation and the safekeeping of identity documents at plants with recruited migrant workers.
- Authority / court
- U.S. Customs and Border Protection
- Area of law
- Supply chain and human rights · Forced and child labour
- Legal basis
- 19 U.S.C. § 1307 (Tariff Act of 1930, Section 307)
- Action
- Order
- Status of proceedings
- unknown
- Sector
- Automotive
- Published
- 18 Dec 2025
- CBP issues Withhold Release Order on Linglong International Europe D.O.O. Zrenjanin Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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3 Dec 2025 Southern Health Solutions, Inc. (Next Medical / NextMed)NextMed: FTC settlement over allegations of hidden costs and review manipulation €128,557
According to the FTC, the telemedicine company advertised GLP-1 weight-loss programmes with monthly prices that did not include medication, laboratory costs and medical consultations, concealed the minimum term and cancellation fees, published fake testimonials from employees and relatives, and induced customers to delete negative reviews by offering vouchers or refunds. Under the final settlement order, the company and its management are paying 150,000 USD, which is earmarked for refunds.
"Buying off" negative reviews with vouchers is just as misleading as inventing positive ones.
Review manipulation and price disclosures
- Authority / court
- Federal Trade Commission (FTC)
- Area of law
- Consumer protection and online retail · Fake reviews
- Legal basis
- Section 5 FTC Act; Restore Online Shoppers' Confidence Act (ROSCA)
- Action
- Disgorgement of profits
- Status of proceedings
- final
- Sector
- Healthcare
- Liability of senior managers
- Founder Robert Epstein and CEO Frank Leonardo III are named in the press release as parties involved.
- Published
- 3 Dec 2025
Original amount 150,000 USD, converted at the ECB reference rate of 3 Dec 2025.
- FTC Takes Action Against Telemedicine Firm NextMed Press release of an authority
- FTC Approves Final Order against Telehealth Provider NextMed (03.12.2025) Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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3 Dec 2025 The Boeing Company und Spirit AeroSystems Holdings, Inc.Boeing/Spirit AeroSystems: takeover only with divestiture of Airbus supplier plants Order
For the 8.3 billion USD takeover of the fuselage and wing supplier Spirit AeroSystems, the Federal Trade Commission (FTC) required Boeing to divest Spirit’s Airbus businesses to Airbus and the plant in Subang, Malaysia, to CTRM, to provide transitional services and to continue supplying defence competitors. A monitor oversees implementation.
Vertical acquisitions of a supplier on which competitors also depend often only go through with divestitures and supply commitments.
- Authority / court
- Federal Trade Commission (FTC)
- Area of law
- Competition law · Merger control
- Legal basis
- Section 7 Clayton Act; Section 5 FTC Act (Consent Order)
- Action
- Order
- Status of proceedings
- unknown
- Sector
- Defence and security
- Employees
- 10,000 or more
- FTC Requires Boeing to Divest Several Spirit Assets to Proceed with Merger (03.12.2025) Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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2 Dec 2025 IPI Partners, LLCPrivate equity firm IPI held oligarch's funds for four years after designation €9.89m
In 2017/2018, the Chicago fund manager specialising in data centres took in capital from the Russian oligarch Suleiman Kerimov via nested structures and continued to manage this investment for four years after his designation in April 2018. The US Treasury's Office of Foreign Assets Control (OFAC) assessed the case as non-egregious and not voluntarily self-disclosed.
Screen investors through to the beneficial owner and re-check them when new designations occur – nested structures do not protect against liability.
Checking beneficial owners of investors and fund structures
- Authority / court
- U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC)
- Area of law
- Sanctions and export control · Breaches of sanctions and embargoes
- Legal basis
- Ukraine-/Russia-Related Sanctions Regulations (31 C.F.R. part 589); IEEPA
- Action
- Fine
- Status of proceedings
- final
- Sector
- Financial services and insurance
- Mitigating circumstances
- No prior violations in five years; cooperation improved significantly only after initially insufficient engagement (including waiver of attorney-client privilege), hence only limited credit
- Published
- 2 Dec 2025
Original amount 11,485,352 USD, converted at the ECB reference rate of 2 Dec 2025.
- OFAC Enforcement Release: IPI Partners, LLC Settles with OFAC for $11,485,352 (02.12.2025) Decision of an authority
- OFAC – 2025 Enforcement Information Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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20 Nov 2025 Caesars Entertainment, Inc. / Desert Palace, LLC (Caesars Palace)Nevada: 7.8 million USD against Caesars over gambling by an illegal bookmaker €6.77m
On 13 November 2025, the Nevada Gaming Control Board (NGCB) filed a disciplinary complaint for unsuitable methods of operation in connection with the illegal bookmaker Mathew Bowyer and at the same time concluded a settlement of 7.8 million USD with conditions attached to the gaming licences. The conditions relate primarily to improving the AML programme and to additional training and awareness-raising for employees; the Nevada Gaming Commission (NGC) adopted the settlement as its order on 20 November 2025 (Case No. 25-03).
Casino staff must recognise high-risk players and unexplained sources of funds – revenue interests must not override AML obligations.
Checking the source of gambling funds, recognising high-risk customers
Missing or inadequate training played a role in the decision.
- Authority / court
- Nevada Gaming Commission (NGC) auf Beschwerde des Nevada Gaming Control Board (NGCB)
- Area of law
- Money laundering and terrorist financing · Customer due diligence
- Legal basis
- Glücksspielrecht Nevada (unsuitable methods of operation)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Other
- Employees
- 10,000 or more
- Mitigating circumstances
- Numerous remedial measures already implemented
- Published
- 13 Nov 2025
Original amount 7,800,000 USD, converted at the ECB reference rate of 20 Nov 2025.
- Nevada Gaming Control Board and Caesars Entertainment, Inc. Enter into Proposed Stipulation for Settlement Regarding Disciplinary Complaint Press release of an authority
- Nevada Gaming Commission – Disposition, November 2025 Agenda (20.11.2025) Decision of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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18 Nov 2025 Firemount Group Ltd.CBP stops clothing from Firemount Group in Mauritius Order
U.S. Customs and Border Protection (CBP) issued a Withhold Release Order: clothing and textiles from Firemount Group Ltd. (Mauritius) are being detained at all US ports of entry because there are indications of forced labour (ILO indicators including abuse of vulnerability, debt bondage, deception, and intimidation and threats).
Suppliers outside traditional high-risk countries must also be checked for their recruitment practices for foreign workers.
- Authority / court
- U.S. Customs and Border Protection
- Area of law
- Supply chain and human rights · Forced and child labour
- Legal basis
- 19 U.S.C. § 1307 (Tariff Act of 1930, Section 307)
- Action
- Order
- Status of proceedings
- unknown
- Sector
- Other
- Published
- 18 Nov 2025
- CBP issues Withhold Release Order on Firemount Group Ltd. Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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14 Nov 2025 Valvoline Inc. und Greenbriar Equity Fund V, L.P.Valvoline/Greenbriar: FTC requires sale of 45 quick oil change shops Order
Valvoline wanted to acquire around 200 Oil Changers shops from Greenbriar for 625 million USD. Because the two competed directly in 25 local markets, under the proposed consent order the acquisition may only be completed if 45 shops are sold to Main Street Auto.
For branch networks too, the competition authority examines each local market individually – map overlaps before the deal.
- Authority / court
- Federal Trade Commission (FTC)
- Area of law
- Competition law · Merger control
- Legal basis
- Section 7 Clayton Act; Section 5 FTC Act (Consent Order)
- Action
- Order
- Status of proceedings
- unknown
- Sector
- Automotive
- FTC Requires Divestiture of Oil Change Shops in Valvoline-Greenbriar Deal (14.11.2025) Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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12 Nov 2025 Comunicaciones Celulares S.A. (TIGO Guatemala)TIGO Guatemala pays more than 118 million USD for bribing members of Congress €102.1m
From 2012 to 2018, the Guatemalan mobile network operator made monthly cash payments to members of Congress or their security staff in order to obtain legislative support; part of the funds came from laundered drug money. Two-year Deferred Prosecution Agreement with a criminal penalty of 60 million USD and administrative forfeiture of 58,198,343 USD.
In joint ventures with local partners, the parent company needs genuine control over cash flows and contacts with public officials – an early voluntary self-disclosure is no substitute for a full investigation.
Bribery of public officials, cash payments, integrity of co-shareholders
- Authority / court
- U.S. Department of Justice (Criminal Division, Fraud Section; USAO Southern District of Florida)
- Area of law
- Bribery and corruption · Bribery of public officials
- Legal basis
- FCPA, 15 U.S.C. § 78dd-3 (Verschwörung, 18 U.S.C. § 371); Deferred Prosecution Agreement
- Action
- Fine
- Status of proceedings
- final
- Sector
- Telecoms, IT and software
- Culpability
- intentional
- Mitigating circumstances
- Voluntary self-disclosure by the parent company Millicom in 2015; subsequently extensive cooperation and remediation (including dismissals of staff and an 800 % increase in compliance personnel).
- Liability of senior managers
- According to the DOJ, the scheme was directed by the then Guatemalan shareholder and other senior individuals; four individuals had already been charged (not named).
- Published
- 12 Dec 2025
Original amount 118,198,343 USD, converted at the ECB reference rate of 12 Nov 2025.
- TIGO Guatemala Paid Over $118M to Resolve Foreign Bribery Investigation Press release of an authority
- Deferred Prosecution Agreement, United States v. Comunicaciones Celulares S.A. d/b/a TIGO Guatemala (Case 1:25-cr-20476) Decision of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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31 Oct 2025 Google LLCTexas: Google pays $1.375 billion over location, incognito and biometric data €1.19bn
Texas, represented by the Office of the Attorney General, had sued Google for unlawfully collecting location data, activity in incognito mode and biometric identifiers. Google signed a settlement of $1.375 billion, concluding two sets of proceedings.
Settings such as location history or incognito mode must deliver what they promise users – otherwise billion-dollar risks loom, even at the level of individual US states.
- Authority / court
- Office of the Attorney General of Texas
- Area of law
- Data protection · Cookies and tracking
- Action
- Other
- Status of proceedings
- final
- Sector
- Telecoms, IT and software
- Employees
- 10,000 or more
- Published
- 31 Oct 2025
Original amount 1,375,000,000 USD, converted at the ECB reference rate of 31 Oct 2025.
- Attorney General Ken Paxton Finalizes Historic Settlement with Google and Secures $1.375 Billion Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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23 Oct 2025 TFG Holding, Inc.JustFab, ShoeDazzle, FabKids: 4.8 million USD settlement with 33 attorneys general over VIP membership €4.14m
According to the allegations of the attorneys general, the online fashion retailer enrolled buyers in a paid VIP membership programme without their express consent, presented prices in a misleading way and made cancellation difficult. Under the settlement with 32 states and D.C., TFG is providing around 3.8 million USD in automatic refunds and paying 1 million USD to the states; the settlement does not constitute an admission of guilt.
A purchase must not silently trigger a membership with monthly charges.
Subscription models and express consent at checkout
- Authority / court
- Attorney General of Pennsylvania (verhandelt mit Maryland, Texas und D.C.; Vergleich mit 33 Attorneys General)
- Area of law
- Consumer protection and online retail · Information duties in online retail
- Legal basis
- Verbraucherschutzgesetze der beteiligten Bundesstaaten
- Action
- Disgorgement of profits
- Status of proceedings
- final
- Sector
- Retail and e-commerce
- Published
- 23 Oct 2025
Original amount 4,800,000 USD, converted at the ECB reference rate of 23 Oct 2025.
- AG Sunday Secures Settlement Valued at $4.8 Million with Online Clothing Retailer Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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21 Oct 2025 Winsor Maintenance Inc., Main Source Group, Inc. u. a. sowie OptumCare Management LLC (Auftraggeberin)Cleaning companies/OptumCare: 438,204 USD – overtime and missed breaks €377,534
More than 90 cleaners in industrial, laboratory and healthcare facilities often worked beyond scheduled hours without overtime pay, received no compensation for split shifts and travel time and were unable to take breaks because of excessive workloads. A web of companies owned by the Hong family concealed the employer; the Notice of Final Findings of 21 October 2025 established 438,204 USD, with OptumCare jointly liable as the client.
Clients of cleaning and service providers should check working hours and breaks at the provider – otherwise they are jointly liable.
- Authority / court
- California Labor Commissioner's Office (Division of Labor Standards Enforcement)
- Area of law
- Health and safety and employment law · Working time
- Legal basis
- California Labor Code § 2810.3; Overtime, Split Shift, Meal and Rest Periods, Mindestlohn
- Action
- Other
- Status of proceedings
- unknown
- Sector
- Other
- Liability of senior managers
- Members of the owning family and an acquaintance cited personally.
- Published
- 24 Nov 2025
Original amount 438,204 USD, converted at the ECB reference rate of 21 Oct 2025.
Checked against the official source on 25 Sep 2026 · Direct link
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14 Oct 2025 Farmers Insurance ExchangeNYDFS: $2.775 million against Farmers over unprotected online quoting tools €2.4m
Attackers harvested driving licence numbers and dates of birth via inadequately secured online quoting tools and agent portals. According to the New York State Department of Financial Services (NYDFS), Farmers infringed the cybersecurity regulation and did not report the incident in time; the penalty is part of a package totalling $19 million against eight motor insurers.
Automatically pre-filled forms containing customer data are a point of entry – scrutinise public-facing applications for the data they disclose.
- Authority / court
- New York State Department of Financial Services (NYDFS)
- Area of law
- Information security and cyber · Security measures and risk management
- Legal basis
- 23 NYCRR Part 500 (Cybersecurity Regulation)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Financial services and insurance
- Culpability
- negligent
- Published
- 14 Oct 2025
Original amount 2,775,000 USD, converted at the ECB reference rate of 14 Oct 2025.
- DFS Secures More than $19 Million from Auto Insurance Companies over Data Breaches Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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14 Oct 2025 Infinity Insurance CompanyInfinity Insurance: 2.25 million USD – data leak via quoting tool reported too late €1.95m
Attackers extracted driver’s licence numbers in plain text via the motor insurer’s instant quote applications. Infinity discovered the anomalies on 9 February 2021 but only reported the cybersecurity event to the New York State Department of Financial Services (NYDFS) on 14 April 2021; the supervisor also criticised the lack of MFA and insecure development practices.
Misuse of publicly accessible customer applications is also a reportable incident – warnings from the supervisor should trigger an immediate reporting assessment.
- Authority / court
- New York State Department of Financial Services (NYDFS)
- Area of law
- Information security and cyber · Incident reporting obligations
- Legal basis
- 23 NYCRR § 500.17(a), § 500.12(a) u. a.
- Action
- Fine
- Status of proceedings
- final
- Sector
- Financial services and insurance
- Culpability
- negligent
Original amount 2,250,000 USD, converted at the ECB reference rate of 14 Oct 2025.
- NYDFS Consent Order to Infinity Insurance Company (14.10.2025) Decision of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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26 Sep 2025 Tractor Supply CompanyCPPA: $1.35 million against Tractor Supply over missing opt-out mechanisms €1.16m
The rural retail giant inadequately informed consumers and job applicants about their rights, offered no effective means of opting out of the sale and sharing of data (including no Global Privacy Control) and passed data on to third parties without the required contracts. An officer must certify compliance annually for four years, as required by the California Privacy Protection Agency (CPPA).
Privacy notices must also cover job applicants, and browser opt-out signals such as GPC must be implemented technically.
- Authority / court
- California Privacy Protection Agency (CPPA)
- Area of law
- Data protection · Data subject rights and transparency
- Legal basis
- California Consumer Privacy Act (CCPA)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Retail and e-commerce
- Employees
- 10,000 or more
- Published
- 30 Sep 2025
Original amount 1,350,000 USD, converted at the ECB reference rate of 26 Sep 2025.
- CPPA: Tractor Supply Company enforcement decision Press release of an authority
- CPPA Order of Decision and Stipulated Final Order: Tractor Supply Company (ENF24-M-TR-04) Decision of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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25 Sep 2025 Amazon.com, Inc.Amazon pays 2.5 billion USD in FTC settlement over Prime sign-up and cancellation hurdles €2.13bn
According to the U.S. Federal Trade Commission (FTC), Amazon used confusing order screens to push millions of customers into Prime subscriptions without their consent and deliberately made cancellation difficult. The settlement comprises a civil penalty of 1 billion USD and 1.5 billion USD in refunds, as well as a clear decline button and simple cancellation.
Subscription sign-ups require an equally prominent option to decline and a cancellation process that is as simple as signing up.
Dark patterns and subscription design in product design
- Authority / court
- Federal Trade Commission (FTC)
- Area of law
- Consumer protection and online retail · Information duties in online retail
- Legal basis
- Restore Online Shoppers' Confidence Act (ROSCA); Section 5 FTC Act
- Action
- Fine
- Status of proceedings
- final
- Sector
- Retail and e-commerce
- Employees
- 10,000 or more
- Liability of senior managers
- The press release names Senior Vice President Neil Lindsay and Vice President Jamil Ghani.
- Published
- 25 Sep 2025
Original amount 2,500,000,000 USD, converted at the ECB reference rate of 25 Sep 2025.
- FTC Secures Historic $2.5 Billion Settlement Against Amazon Press release of an authority
- FTC Case: Amazon.com, Inc. (ROSCA), FTC v. – Stipulated Order entered by the Court 25.09.2025 Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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24 Sep 2025 Giant Manufacturing Co. Ltd.CBP detains bicycles from Giant Manufacturing over forced labour Order
U.S. Customs and Border Protection (CBP) issued a Withhold Release Order: bicycles, bicycle parts and accessories from Giant Manufacturing Co. Ltd. (Taiwan) are being detained at all US ports of entry because there are indications of forced labour (ILO indicators including debt bondage, withholding of wages, excessive overtime and abusive working and living conditions). Detained shipments can be destroyed, re-exported or released upon proof of admissibility.
Recruitment fees for migrant workers are a core risk – suppliers should demonstrably bear them themselves.
- Authority / court
- U.S. Customs and Border Protection
- Area of law
- Supply chain and human rights · Forced and child labour
- Legal basis
- 19 U.S.C. § 1307 (Tariff Act of 1930, Section 307)
- Action
- Order
- Status of proceedings
- unknown
- Sector
- Manufacturing and mechanical engineering
- Published
- 24 Sep 2025
- CBP issues Withhold Release Order on Giant Manufacturing Co. Ltd. Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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18 Sep 2025 Chegg Inc.Chegg pays 7.5 million USD in FTC settlement over allegations of obstructed subscription cancellation €6.35m
According to the FTC complaint, the education provider hid the cancellation option for its automatically renewing subscriptions on its website and, since October 2020, continued to charge almost 200,000 customers even after they had cancelled. Under the settlement, Chegg is paying 7.5 million USD for refunds and must offer simple cancellation.
Cancellations received must be reliably implemented in the systems – continuing to charge customers is a separate violation.
Cancellation processes and customer service for subscriptions
- Authority / court
- Federal Trade Commission (FTC)
- Area of law
- Consumer protection and online retail · Information duties in online retail
- Legal basis
- Restore Online Shoppers' Confidence Act (ROSCA); Section 5 FTC Act
- Action
- Disgorgement of profits
- Status of proceedings
- final
- Sector
- Telecoms, IT and software
- Repeat case
- yes
- Published
- 15 Sep 2025
Original amount 7,500,000 USD, converted at the ECB reference rate of 18 Sep 2025.
Checked against the official source on 25 Sep 2026 · Direct link
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4 Sep 2025 Midri, Inc. (Restaurant J BBQ, Los Angeles)Restaurant J BBQ: 680,238 USD – breaks denied, split shifts without premium €584,046
The Koreatown restaurant regularly denied 48 employees meal and rest breaks, required them to remain available for guests even during the lunch break, did not pay split-shift premiums and did not pay all wages. The California Labor Commissioner’s Office imposed 680,238 USD, of which 538,638 USD for the benefit of the employees.
In the restaurant trade, breaks must be actively scheduled and documented – being on call for guests during the break turns it into working time.
Break arrangements in the restaurant trade
- Authority / court
- California Labor Commissioner's Office (Division of Labor Standards Enforcement)
- Area of law
- Health and safety and employment law · Working time
- Legal basis
- California Labor Code (Meal and Rest Periods, Split Shift Premium, Lohnabrechnung)
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Food and agriculture
- Liability of senior managers
- Owner Byung Kwan Lee named in the announcement.
Original amount 680,238 USD, converted at the ECB reference rate of 4 Sep 2025.
Checked against the official source on 25 Sep 2026 · Direct link
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3 Sep 2025 Fracht FWO Inc.Freight forwarder Fracht FWO chartered blocked Venezuelan airline with Mahan Air jet €1.38m
In May 2022, bypassing internal compliance procedures, the Houston freight forwarder engaged a blocked Venezuelan state-owned airline for a shipment from Mexico to Argentina; the aircraft used, which was also blocked, was operated by Iran's Mahan Air. The US Treasury's Office of Foreign Assets Control (OFAC) classified the case as egregious and not voluntarily self-disclosed, partly because two vice presidents bypassed the screening under time pressure.
Urgent customer orders never justify skipping sanctions screening of carriers and of the aircraft or vessels used.
Business partner screening under time pressure, circumvention of internal approvals
- Authority / court
- U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC)
- Area of law
- Sanctions and export control · Breaches of sanctions and embargoes
- Legal basis
- Venezuela-, Iran-, Proliferations- und Terrorismus-Sanktionsprogramme (OFAC); IEEPA
- Action
- Fine
- Status of proceedings
- final
- Sector
- Transport, logistics and shipping
- Culpability
- negligent
- Repeat case
- no
- Mitigating circumstances
- No prior violations in five years, immediate remediation, substantial cooperation
- Liability of senior managers
- According to OFAC, the violation was driven primarily by two vice presidents who bypassed internal screening processes.
- Published
- 3 Sep 2025
Original amount 1,610,775 USD, converted at the ECB reference rate of 3 Sep 2025.
- OFAC Enforcement Release: Fracht FWO Inc. Settles with OFAC for $1,610,775 (03.09.2025) Decision of an authority
- OFAC – 2025 Enforcement Information Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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27 Aug 2025 V.Ships Norway A.S.V.Ships Norway: 2 million USD fine for oil pollution and falsified oil record books €1.73m
On board the tanker M/T Swift Winchester, a hose connected the incinerator's waste oil tank to the sewage tank from February to August 2022, so that oily waste bypassed the pollution prevention equipment and went into the sea; in August 2022, an oily water separator filter was also hosed down with degreaser on deck and the oily mixture ran overboard. The vessel called at Baton Rouge and Port Arthur with a knowingly falsified oil record book. The ship management company pleaded guilty and is paying a fine of 2 million USD.
When a crew member reports misconduct to management, the company must intervene immediately; otherwise it is liable for the continued pollution.
Handling oil residues on board and honest documentation
- Authority / court
- U.S. District Court for the Eastern District of Texas (Anklage: DOJ Environment and Natural Resources Division)
- Area of law
- Environment and sustainability · Waste and hazardous substances
- Legal basis
- Act to Prevent Pollution from Ships (APPS)
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Transport, logistics and shipping
- Culpability
- intentional
- Published
- 27 Aug 2025
Original amount 2,000,000 USD, converted at the ECB reference rate of 27 Aug 2025.
- Shipping Company Fined $2M for Maritime Pollution Offense Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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14 Aug 2025 Healthplex, Inc.Healthplex: 2 million USD – phishing incident not reported to supervisor for months €1.71m
An employee of the dental insurance service provider disclosed his login credentials via a phishing e-mail; the mailbox containing over 100,000 e-mails with health and social security data was accessible. Healthplex had known about the incident since November 2021 but only reported it to the New York State Department of Financial Services (NYDFS) in April 2022 instead of within 72 hours; in addition, there was no MFA for web access and no data retention and deletion policy.
Security incidents require a fixed reporting process with deadline control – the 72-hour clock starts when the incident is identified, not when forensics is completed.
Recognising phishing; reporting channels for security incidents
- Authority / court
- New York State Department of Financial Services (NYDFS)
- Area of law
- Information security and cyber · Incident reporting obligations
- Legal basis
- 23 NYCRR § 500.17(a), § 500.12(b), § 500.13, § 500.17(b)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Financial services and insurance
- Culpability
- negligent
Original amount 2,000,000 USD, converted at the ECB reference rate of 14 Aug 2025.
- NYDFS Consent Order to Healthplex, Inc. (14.08.2025) Decision of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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7 Aug 2025 Paxos Trust Company, LLCNYDFS: 26.5 million USD against Paxos over AML deficiencies in Binance business €22.8m
The New York State Department of Financial Services (NYDFS) imposed a penalty of 26.5 million USD on the crypto trust company because Paxos did not maintain an effective BSA/AML programme before 2023: KYC checks and risk ratings were inadequate, and transaction monitoring and suspicious activity reporting procedures had gaps, including in connection with the business relationship with Binance, contrary to a 2020 agreement. In addition, Paxos must invest at least 22 million USD in its compliance programme.
Companies that distribute products via partner platforms must include those platforms' customer and transaction risks in their own AML programme.
- Authority / court
- New York State Department of Financial Services (NYDFS)
- Area of law
- Money laundering and terrorist financing · Customer due diligence
- Legal basis
- New York Banking Law §§ 39, 44; AML-Vorschriften des NYDFS und Bank Secrecy Act
- Action
- Fine
- Status of proceedings
- final
- Sector
- Financial services and insurance
- Published
- 7 Aug 2025
Original amount 26,500,000 USD, converted at the ECB reference rate of 7 Aug 2025.
- In the Matter of Paxos Trust Company, LLC – Consent Order Decision of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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7 Aug 2025 Liberty Mutual Insurance CompanyLiberty Mutual: declination against 4.7 million USD after bribery of Indian state bank employees €4.04m
From 2017 to 2022, the Indian subsidiary Liberty General Insurance paid around 1.47 million USD to employees of six state-owned banks so that they would refer bank customers to its insurance products; the payments were booked as marketing expenses and routed through third parties. The DOJ declined to prosecute; Liberty Mutual is disgorging 4,699,088 USD in profits.
Employees of state-owned banks are public officials – sales commissions paid to them are bribes, even if they are booked as marketing.
Distribution partnerships with state-owned banks, payments disguised as marketing
- Authority / court
- U.S. Department of Justice (Fraud Section; USAO District of Massachusetts)
- Area of law
- Bribery and corruption · Bribery of public officials
- Legal basis
- FCPA, 15 U.S.C. § 78dd-2; Corporate Enforcement and Voluntary Self-Disclosure Policy (Declination)
- Action
- Disgorgement of profits
- Status of proceedings
- final
- Sector
- Financial services and insurance
- Employees
- 10,000 or more
- Culpability
- intentional
- Mitigating circumstances
- Voluntary self-disclosure (March 2024), full cooperation, root cause analysis, termination of those involved, improved controls including rules on messaging apps.
- Published
- 7 Aug 2025
Original amount 4,699,088 USD, converted at the ECB reference rate of 7 Aug 2025.
- DOJ Declination Letter – Liberty Mutual Insurance Company (07.08.2025) Decision of an authority
- DOJ Criminal Division: CEP Declinations Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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31 Jul 2025 Aero Turbine Inc.; Gallant Capital Partners LLCAero Turbine and Gallant pay 1.75 million USD after self-disclosure on cyber obligations €1.53m
From 2018 to 2020, the engine maintenance company allegedly failed to implement the NIST controls of an Air Force contract and, in 2019, together with its private equity owner, passed files containing sensitive defence data to an unauthorised software company in Egypt. The companies had made several written self-disclosures, cooperated and remedied the issues promptly; the U.S. Department of Justice (DOJ) granted them cooperation credit for this. Settlement of 1.75 million USD.
Companies that pass controlled defence data to service providers must check their authorisation – self-disclosure and cooperation significantly reduce the consequences.
Handling controlled defence data and service providers
- Authority / court
- U.S. Department of Justice (Civil Division) / USAO Eastern District of California
- Area of law
- Other
- Legal basis
- False Claims Act; NIST SP 800-171
- Action
- Other
- Status of proceedings
- final
- Sector
- Defence and security
- Mitigating circumstances
- Several written self-disclosures, cooperation and prompt remedial measures.
- Published
- 31 Jul 2025
Original amount 1,750,000 USD, converted at the ECB reference rate of 31 Jul 2025.
Checked against the official source on 25 Sep 2026 · Direct link
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28 Jul 2025 Cadence Design Systems Inc.Cadence pleads guilty: chip design software for Chinese military university €120.1m
From 2015 to 2021, the San José provider of chip design software supplied hardware, software and semiconductor IP at least 59 times to the National University of Defense Technology (NUDT), a military university on the Entity List, disguised under the alias Central South CAD Center. Cadence pleaded guilty before the US Department of Justice to conspiracy to commit export control violations; criminal penalties of almost 118 million USD and civil penalties of more than 95 million USD imposed by the Bureau of Industry and Security (BIS) result, after crediting, in a net total of more than 140 million USD.
Include cover names and known aliases of listed customers in screening; sales and compliance must escalate indications of military end users.
Recognising aliases and cover names of listed customers
- Authority / court
- U.S. Department of Justice; Bureau of Industry and Security (BIS)
- Area of law
- Sanctions and export control · Export control and dual-use goods
- Legal basis
- Export Administration Regulations (Entity List); ECRA; Verschwörung zu Exportkontrollverstößen
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Telecoms, IT and software
- Employees
- 10,000 or more
- Culpability
- intentional
- Published
- 28 Jul 2025
Original amount 140,000,000 USD, converted at the ECB reference rate of 28 Jul 2025.
- DOJ: Cadence Design Systems Agrees to Plead Guilty and Pay Over $140 Million for Unlawfully Exporting to Military University in China (28.07.2025) Press release of an authority
- BIS: Cadence Design Systems to Pay $95 Million Penalty to BIS for Unauthorized Exports to Chinese Entities (28.07.2025) Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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9 Jul 2025 Wise US, Inc.Six US states: 4.2 million USD against Wise US over AML programme deficiencies €3.59m
In a coordinated multistate proceeding brought by six states – the New York State Department of Financial Services (NYDFS) with the supervisory authorities of CA, MN, NE, TX and MA – the money transmitter must pay 4.2 million USD. An examination (July 2022 to September 2023) found, among other things, a lack of independent AML reviews at an appropriate frequency, late suspicious activity reports, data quality problems in transaction monitoring and unremedied earlier findings; Wise does not admit any legal infringements and must conduct a lookback.
Remedy findings from earlier examinations and audits on time – otherwise they become a ground for sanctions in their own right.
- Authority / court
- New York State Department of Financial Services (NYDFS) mit den Aufsichtsbehörden von CA, MN, NE, TX und MA
- Area of law
- Money laundering and terrorist financing · Suspicious activity reports
- Legal basis
- Bundes- und einzelstaatliches Recht zu Geldtransfer und BSA/AML (u. a. 31 CFR 1022.320)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Financial services and insurance
- Mitigating circumstances
- Remedial measures already initiated and lookback
- Published
- 9 Jul 2025
Original amount 4,200,000 USD, converted at the ECB reference rate of 9 Jul 2025.
- Consent Order – Wise US, Inc. (Multi-State) Decision of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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2 Jul 2025 Key Holding, LLCLogistics company Key Holding: Colombian subsidiary organised 36 shipments to Cuba €517,929
After the acquisition of a Colombian logistics company in December 2021, the latter organised 36 freight shipments to Cuba worth around 3.06 million USD up to July 2023. Neither the US parent nor the subsidiary had a sanctions compliance programme for foreign companies; the US Treasury's Office of Foreign Assets Control (OFAC) assessed the case as non-egregious and voluntarily self-disclosed.
After an acquisition, roll out the sanctions compliance programme to the new foreign subsidiary immediately – the Cuba embargo applies to US-controlled subsidiaries worldwide.
Sanctions compliance after acquisitions
- Authority / court
- U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC)
- Area of law
- Sanctions and export control · Breaches of sanctions and embargoes
- Legal basis
- Cuban Assets Control Regulations (31 C.F.R. part 515)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Transport, logistics and shipping
- Culpability
- negligent
- Repeat case
- no
- Mitigating circumstances
- Voluntary self-disclosure, no prior violations, remedial measures after discovery
- Published
- 2 Jul 2025
Original amount 608,825 USD, converted at the ECB reference rate of 2 Jul 2025.
- OFAC Enforcement Release: Key Holding, LLC Settles with OFAC for $608,825 (02.07.2025) Decision of an authority
- OFAC – 2025 Enforcement Information Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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1 Jul 2025 Healthline Media LLCCalifornia: $1.55 million against Healthline over disclosure of illness-related article titles €1.31m
Despite objections, the health portal continued to pass data to advertising partners and transmitted article titles suggestive of diagnoses for targeted advertising; the consent banner did not stop the tracking. In addition, the required contractual clauses with advertising partners were missing. The settlement was reached with the Attorney General of California.
Test consent banners technically: if rejecting does not actually switch off tracking, that is misleading and unlawful.
- Authority / court
- Attorney General of California (California Department of Justice)
- Area of law
- Data protection · Cookies and tracking
- Legal basis
- California Consumer Privacy Act (CCPA), Unfair Competition Law
- Action
- Fine
- Status of proceedings
- final
- Sector
- Media and online platforms
- Published
- 1 Jul 2025
Original amount 1,550,000 USD, converted at the ECB reference rate of 1 Jul 2025.
- Attorney General Bonta Announces Largest CCPA Settlement to Date, Secures $1.55 Million from Healthline.com Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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16 Jun 2025 Unicat Catalyst Technologies, LLCCatalyst manufacturer Unicat supplied Iran and blocked Venezuelan company €3.35m
In 2016–2021, the Texas supplier of catalysts for refineries and steelworks supplied products and advice to customers in Iran via its former CEO, employees and agents, and sold goods to a blocked Venezuelan company. The US Treasury's Office of Foreign Assets Control (OFAC) considered it an egregious but voluntarily self-disclosed case; there were parallel settlements with the DOJ and BIS, which were taken into account in determining the amount.
When senior management itself steers embargo business, only independent controls and whistleblower channels help – voluntary self-disclosure after discovery reduces the penalty but does not prevent it.
- Authority / court
- U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC)
- Area of law
- Sanctions and export control · Breaches of sanctions and embargoes
- Legal basis
- Iranian Transactions and Sanctions Regulations; Venezuela Sanctions Regulations; IEEPA
- Action
- Fine
- Status of proceedings
- final
- Sector
- Chemicals and pharmaceuticals
- Culpability
- intentional
- Mitigating circumstances
- Voluntary self-disclosure, cooperation and remedial measures after discovery
- Liability of senior managers
- According to OFAC, the violations were carried out by the former CEO and co-founder as well as former employees.
- Published
- 16 Jun 2025
Original amount 3,882,797 USD, converted at the ECB reference rate of 16 Jun 2025.
- OFAC Enforcement Release: Unicat Catalyst Technologies, LLC Settles with OFAC for $3,882,797 (16.06.2025) Decision of an authority
- OFAC – 2025 Enforcement Information Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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22 May 2025 L3 Technologies Inc.L3 Technologies pays 62 million USD over false cost data for communications technology €54.8m
Between October 2006 and February 2014, the Communications System West division allegedly failed to disclose complete and current cost and pricing data when selling ROVER, VORTEX and SIR receivers to the Air Force, Army, Navy and other agencies. Settlement under the False Claims Act and the Truth in Negotiations Act of 62 million USD.
In fixed-price negotiations with the government, costing data must be disclosed completely and on a current basis; price review processes belong in the compliance system.
- Authority / court
- U.S. Department of Justice (Civil Division) / USAO District of Utah
- Area of law
- Other
- Legal basis
- False Claims Act; Truth in Negotiations Act
- Action
- Other
- Status of proceedings
- final
- Sector
- Defence and security
- Employees
- 10,000 or more
- Published
- 22 May 2025
Original amount 62,000,000 USD, converted at the ECB reference rate of 22 May 2025.
Checked against the official source on 25 Sep 2026 · Direct link
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14 May 2025 Norfolk Southern Railway CompanyNorfolk Southern: EPA fine for locomotives without valid emissions certification €266,631
In the view of the U.S. Environmental Protection Agency (EPA), the freight railway operated locomotives without a certificate of conformity, did not comply with the conditions of a testing exemption for several locomotives and operated locomotives in breach of the applicable emission standards. Under the settlement (Consent Agreement and Final Order), the company is paying a civil penalty of 299,000 USD.
Converted vehicles or vehicles exempted for testing are also subject to certification and restoration obligations, which must be tracked in fleet management.
- Authority / court
- U.S. Environmental Protection Agency (EPA), Region 3
- Area of law
- Environment and sustainability · Emissions and permits
- Legal basis
- Clean Air Act §§ 203(a), 213(d) (42 U.S.C. §§ 7522(a), 7547(d)); 40 C.F.R. § 1068.101
- Action
- Fine
- Status of proceedings
- final
- Sector
- Transport, logistics and shipping
- Employees
- 10,000 or more
Original amount 299,000 USD, converted at the ECB reference rate of 14 May 2025.
- In the Matter of Norfolk Southern Railway Company, EPA Docket No. CAA-03-2025-0062, Consent Agreement and Final Order Decision of an authority
- 2025 Clean Air Act Vehicle and Engine Enforcement Case Resolutions Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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6 May 2025 Todd Snyder, Inc.Todd Snyder: 345,178 USD – tracking opt-out ineffective for 40 days €304,793
For 40 days, the fashion retailer’s misconfigured privacy portal did not process objections to the sale and sharing of personal data; in addition, the company required too much data and identity verification before an opt-out. The California Privacy Protection Agency (CPPA) imposed 345,178 USD and required correct configuration of consent management and employee training.
A consent management platform does not relieve companies of responsibility: check regularly whether opt-outs are actually implemented technically.
Configuration and monitoring of consent management platforms
Missing or inadequate training played a role in the decision.
- Authority / court
- California Privacy Protection Agency (CPPA), Board
- Area of law
- Data protection · Cookies and tracking
- Legal basis
- California Consumer Privacy Act (CCPA)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Retail and e-commerce
Original amount 345,178 USD, converted at the ECB reference rate of 6 May 2025.
- CPPA Orders Clothing Retailer Todd Snyder to Pay Six-Figure Fine, Overhaul Privacy Practices (06.05.2025) Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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1 May 2025 Raytheon Company; RTX Corporation; Nightwing Group LLC; Nightwing Intelligence Solutions LLCRaytheon and Nightwing pay 8.4 million USD over cybersecurity deficiencies in DoD contracts €7.39m
Between 2015 and 2021, the companies allegedly failed to prepare a system security plan for an internal development system used for 29 Department of Defense contracts and did not comply with the clauses DFARS 252.204-7012 and FAR 52.204-21. Settlement under the False Claims Act of 8.4 million USD; a former director of engineering received 1.512 million USD as a whistleblower.
Internal development environments are also covered by contractual cybersecurity obligations and need a documented security plan.
- Authority / court
- U.S. Department of Justice (Civil Division) / USAO District of Columbia
- Area of law
- Other
- Legal basis
- False Claims Act; DFARS 252.204-7012; FAR 52.204-21
- Action
- Other
- Status of proceedings
- final
- Sector
- Defence and security
- Employees
- 10,000 or more
- Published
- 1 May 2025
Original amount 8,400,000 USD, converted at the ECB reference rate of 30 Apr 2025.
Checked against the official source on 25 Sep 2026 · Direct link
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28 Apr 2025 Gilead Sciences, Inc.Gilead: 202 million USD – speaker programmes with fees, luxury meals and travel €177.8m
Gilead paid physicians who spoke at or attended events on its HIV medicines fees, meals and travel expenses to promote prescriptions; high prescribers received hundreds of thousands of dollars, and events took place at luxury restaurants. The court-approved settlement of 202 million USD contains extensive admissions of fact.
Selecting speakers by prescription volume turns continuing education into bribery – selection criteria and hospitality limits must be documented.
Fees and hospitality at professional events
- Authority / court
- U.S. Attorney's Office, Southern District of New York; U.S. District Court (S.D.N.Y.)
- Area of law
- Bribery and corruption · Gifts, hospitality and benefits
- Legal basis
- Anti-Kickback Statute (42 U.S.C. § 1320a-7b(b)); False Claims Act (31 U.S.C. §§ 3729 ff.)
- Action
- Other
- Status of proceedings
- final
- Sector
- Chemicals and pharmaceuticals
- Employees
- 10,000 or more
- Published
- 29 Apr 2025
Original amount 202,000,000 USD, converted at the ECB reference rate of 28 Apr 2025.
- HHS-OIG Enforcement Actions: U.S. Attorney Announces $202 Million Settlement With Gilead Sciences … Speaker Programs (29.04.2025) Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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10 Apr 2025 Block, Inc.NYDFS: 40 million USD against Block (Cash App) over AML deficiencies €36.1m
The New York State Department of Financial Services (NYDFS) imposed 40 million USD on the operator of Cash App for serious gaps in its BSA/AML programme, including insufficient customer due diligence, a lack of risk-based controls and untimely transaction monitoring. Rapid growth in 2019/2020 led to a considerable backlog of alerts; an independent monitor is being appointed.
Scale compliance capacity with growth – a backlog of alerts is a supervisory infringement in its own right.
- Authority / court
- New York State Department of Financial Services (NYDFS)
- Area of law
- Money laundering and terrorist financing · Customer due diligence
- Legal basis
- BSA/AML-, Geldtransfer- und Virtual-Currency-Vorschriften des NYDFS
- Action
- Fine
- Status of proceedings
- final
- Sector
- Financial services and insurance
- Employees
- 10,000 or more
- Mitigating circumstances
- Cooperation and remedial measures already initiated
- Published
- 10 Apr 2025
Original amount 40,000,000 USD, converted at the ECB reference rate of 10 Apr 2025.
Checked against the official source on 25 Sep 2026 · Direct link
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3 Apr 2025 Taepyung Salt FarmCBP import stop for sea salt from South Korea's Taepyung Salt Farm Order
U.S. Customs and Border Protection (CBP) issued a Withhold Release Order: sea salt products from Taepyung Salt Farm (South Korea) are being detained at all US ports of entry because there are indications of forced labour (ILO indicators including physical violence, debt bondage, deception, restriction of movement and withholding of wages (ten indicators)).
Food manufacturers should also include inconspicuous ingredients such as salt in their forced labour risk analysis.
- Authority / court
- U.S. Customs and Border Protection
- Area of law
- Supply chain and human rights · Forced and child labour
- Legal basis
- 19 U.S.C. § 1307 (Tariff Act of 1930, Section 307)
- Action
- Order
- Status of proceedings
- unknown
- Sector
- Food and agriculture
- Published
- 3 Apr 2025
- CBP issues Withhold Release Order on Taepyung Salt Farm Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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19 Mar 2025 Hino Motors, Ltd.Hino Motors: over 1.6 billion USD in fines and forfeiture for emissions fraud €1.48bn
Between 2010 and 2019, the Toyota subsidiary submitted false certification applications, altered emissions data and fabricated test results; more than 105,000 non-compliant diesel engines were imported into the USA. The court imposed a fine of 521.76 million USD and forfeiture of 1.087 billion USD, plus five years of probation with an import ban on Hino diesel engines.
Manipulated test data in approval procedures lead to penalties that threaten a company's existence and to market bans; testing processes need independent controls.
Data integrity in testing and approval procedures
- Authority / court
- U.S. District Court for the Eastern District of Michigan (Ermittlungen: EPA Criminal Investigation Division, FBI)
- Area of law
- Environment and sustainability · Emissions and permits
- Legal basis
- Clean Air Act; Verschwörung zum Betrug der Vereinigten Staaten und Schmuggel (Schuldbekenntnis)
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Automotive
- Employees
- 10,000 or more
- Culpability
- intentional
- Published
- 19 Mar 2025
Original amount 1,608,760,000 USD, converted at the ECB reference rate of 19 Mar 2025.
- Court Sentences Hino Motors Ltd., a Toyota Subsidiary, and Imposes Over $1.6B in Penalties for Emissions Fraud Scheme Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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7 Mar 2025 American Honda Motor Co., Inc.CPPA: $632,500 against Honda over obstructed privacy requests €582,573
Honda required excessive information for opt-out requests, used a cookie tool without equivalent choices, made it harder to appoint authorised agents and passed data on to ad-tech firms without the required contracts. The order of the California Privacy Protection Agency (CPPA) requires, among other things, a simplified procedure and training for employees.
Do not undermine data subject rights through form hurdles or asymmetric consent dialogues.
- Authority / court
- California Privacy Protection Agency (CPPA)
- Area of law
- Data protection · Data subject rights and transparency
- Legal basis
- California Consumer Privacy Act (CCPA)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Automotive
- Employees
- 10,000 or more
- Published
- 12 Mar 2025
Original amount 632,500 USD, converted at the ECB reference rate of 7 Mar 2025.
- CPPA: Enforcement action against American Honda Motor Co. Press release of an authority
- CPPA Order of Decision: American Honda Motor Co., Inc. (ENF23-V-HO-2) Decision of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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6 Feb 2025 Lockheed Martin CorporationLockheed Martin pays 29.74 million USD over inflated price proposals for the F-35 €28.7m
From 2013 to 2015, Lockheed Martin allegedly failed to provide the Joint Program Office with accurate cost and pricing data for five production and sustainment contracts for the F-35 programme and thereby obtained inflated prices. The settlement amounts to 29.74 million USD, in addition to 11.3 million USD that had already been paid to the Department of Defense; it was triggered by a qui tam action.
Whistleblower actions from within the company make pricing errors costly even years later – internal reporting channels must pick up such issues early.
- Authority / court
- U.S. Department of Justice (Civil Division) / USAO Eastern District of Texas
- Area of law
- Other
- Legal basis
- False Claims Act; Truth in Negotiations Act
- Action
- Other
- Status of proceedings
- final
- Sector
- Defence and security
- Employees
- 10,000 or more
- Published
- 6 Feb 2025
Original amount 29,740,000 USD, converted at the ECB reference rate of 6 Feb 2025.
- Lockheed Martin Corporation Agrees to Settle False Claims Act Allegations of Defective Pricing Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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23 Jan 2025 PayPal, Inc.NYDFS: $2 million against PayPal over untrained teams and missing MFA €1.92m
When changing data flows for 1099-K tax forms, insufficiently trained teams bypassed security processes; criminals with compromised credentials were able to retrieve forms containing social security numbers. According to the New York State Department of Financial Services (NYDFS), qualified personnel, training, access policies as well as MFA, CAPTCHA and rate limiting were lacking.
Anyone changing data flows must know the security processes – training development teams is part of cyber defence.
Secure software development and change processes
Missing or inadequate training played a role in the decision.
- Authority / court
- New York State Department of Financial Services (NYDFS)
- Area of law
- Information security and cyber · Security measures and risk management
- Legal basis
- 23 NYCRR Part 500 (Cybersecurity Regulation)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Financial services and insurance
- Employees
- 10,000 or more
- Culpability
- negligent
- Mitigating circumstances
- PayPal has since remedied the deficiencies.
- Published
- 23 Jan 2025
Original amount 2,000,000 USD, converted at the ECB reference rate of 23 Jan 2025.
- DFS-Pressemitteilung vom 23.01.2025: Cybersecurity-Vergleich mit PayPal, Inc. (2 Mio. $) Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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17 Jan 2025 Haas Automation, Inc.Haas Automation: CNC parts and unlock codes for blocked Russian defence companies €1.01m
According to the US Treasury's Office of Foreign Assets Control (OFAC), from December 2019 to March 2022 the Californian machine tool manufacturer indirectly supplied, via its dealer network, one CNC machine, 13 spare parts orders and seven unlock codes for machines of blocked Russian defence and energy companies. According to OFAC, Haas agreed to a settlement of 1,044,781 USD with OFAC (OFAC treated eight of the 21 apparent violations as egregious; no voluntary self-disclosure); at the same time, Haas reached a separate settlement of 1.5 million USD with the US Commerce Department's Bureau of Industry and Security (BIS), which is not included in the amount shown. Source: U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC), enforcement release "Haas Automation, Inc. Settles with OFAC for $1,044,781 for Apparent Violations of the Ukraine-/Russia-related Sanctions Regulations", 17 January 2025, https://ofac.treasury.gov/media/933956/download?inline; summarised in our own words.
Spare parts and software unlock codes for machines already delivered are also services relevant to sanctions – end customers behind dealers must be known.
End-customer screening in dealer sales, software unlocks as a service
- Authority / court
- U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC); parallel U.S. Department of Commerce, Bureau of Industry and Security (BIS)
- Area of law
- Sanctions and export control · Breaches of sanctions and embargoes
- Legal basis
- Ukraine-/Russia-Related Sanctions Regulations (31 C.F.R. part 589; E.O. 13662); Export Administration Regulations
- Action
- Fine
- Status of proceedings
- final
- Sector
- Manufacturing and mechanical engineering
- Mitigating circumstances
- Substantial remedial measures and extensive cooperation
- Published
- 17 Jan 2025
Original amount 1,044,781 USD, converted at the ECB reference rate of 17 Jan 2025.
- OFAC Enforcement Release: Haas Automation, Inc. Settles with OFAC for $1,044,781 (17.01.2025) Decision of an authority
- OFAC – 2025 Enforcement Information Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Version 2 · Direct link
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16 Jan 2025 Two Sigma Investments LP und Two Sigma Advisers LPTwo Sigma: 90 million USD – known weaknesses in investment models left unremedied for years €87.6m
Employees identified weaknesses in investment models that could affect client returns by March 2019 at the latest, but Two Sigma only acted in August 2023; there were no policies, and one employee made unauthorised changes to more than a dozen models. In addition, separation agreements required employees to declare that they had not filed any complaint with authorities. The U.S. Securities and Exchange Commission (SEC) imposed 90 million USD; Two Sigma had already repaid 165 million USD to clients.
Model risks need a change and approval procedure – and identified weaknesses need a binding deadline for remediation.
- Authority / court
- U.S. Securities and Exchange Commission (SEC)
- Area of law
- Capital markets and financial supervision · Organisational requirements
- Legal basis
- Investment Advisers Act of 1940 (Antifraud, Compliance Rule 206(4)-7); Exchange Act Rule 21F-17(a)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Financial services and insurance
- Culpability
- intentional
- Mitigating circumstances
- Voluntary repayment of 165 million USD to affected funds and accounts.
Original amount 90,000,000 USD, converted at the ECB reference rate of 16 Jan 2025.
- SEC Charges Two Sigma for Failing to Address Known Vulnerabilities in its Investment Models (16.01.2025) Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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15 Jan 2025 Hino Motors, Ltd.; Hino Motors Manufacturing U.S.A., Inc.; Hino Motors Sales U.S.A., Inc.Hino Motors: over 1 billion USD in penalties for falsified emissions test data €1.02bn
From 2010 to 2019, the Toyota subsidiary altered test data, carried out tests improperly or fabricated them entirely for more than 50 engine families (around 105,000 on-road and 5,700 off-road diesel engines). The resolution with the U.S. Environmental Protection Agency (EPA) and the U.S. Department of Justice comprises a civil penalty of 525 million USD and a criminal fine of 521.76 million USD (together 1.047 billion USD), five years of probation and an import ban on diesel engines; including the recall and mitigation measures, the overall resolution totals more than 1.6 billion USD.
Certification data is evidence – companies that embellish test results risk their existence, loss of market access and criminal prosecution.
Integrity of test and certification data
- Authority / court
- U.S. Environmental Protection Agency / U.S. Department of Justice
- Area of law
- Environment and sustainability · Emissions and permits
- Legal basis
- Clean Air Act
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Automotive
- Culpability
- intentional
Original amount 1,046,760,000 USD, converted at the ECB reference rate of 15 Jan 2025.
- Hino Motors Clean Air Act Settlement Summary Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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15 Jan 2025 Donghai JA Solar Technology Co., Ltd.UFLPA list: solar manufacturer Donghai JA Solar Technology added Order
The U.S. Forced Labor Enforcement Task Force (FLETF) added the manufacturer of silicon ingots, wafers and solar modules from Jiangsu Province to the Uyghur Forced Labor Prevention Act (UFLPA) Entity List because it sources material from Xinjiang. The company's goods are therefore presumed to have been produced with forced labour on import into the US unless the importer rebuts this.
Companies procuring solar modules should have the origin of the polysilicon documented without gaps.
- Authority / court
- U.S. Department of Homeland Security (Forced Labor Enforcement Task Force)
- Area of law
- Supply chain and human rights · Forced and child labour
- Legal basis
- Uyghur Forced Labor Prevention Act, Section 2(d)(2)(B)(v)
- Action
- Order
- Status of proceedings
- unknown
- Sector
- Energy and utilities
- Published
- 15 Jan 2025
- Federal Register: Notice Regarding the Uyghur Forced Labor Prevention Act Entity List (15.01.2025) Official register or notice
Checked against the official source on 25 Sep 2026 · Direct link
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15 Jan 2025 Xinjiang Zijin Zinc Industry Co., Ltd.UFLPA list: zinc producer Xinjiang Zijin Zinc Industry added Order
The U.S. Forced Labor Enforcement Task Force (FLETF) listed the mining company from Kizilsu Prefecture on two grounds: for working with the Xinjiang government on the recruitment and transfer of persecuted groups, and for sourcing material from Xinjiang. The company's goods are therefore presumed to have been produced with forced labour on import into the US unless the importer rebuts this.
Metal processors should know the smelters and mines of their upstream suppliers and screen them against the UFLPA Entity List.
- Authority / court
- U.S. Department of Homeland Security (Forced Labor Enforcement Task Force)
- Area of law
- Supply chain and human rights · Forced and child labour
- Legal basis
- Uyghur Forced Labor Prevention Act, Section 2(d)(2)(B)(ii) und (v)
- Action
- Order
- Status of proceedings
- unknown
- Sector
- Steel and metals
- Published
- 15 Jan 2025
- Federal Register: Notice Regarding the Uyghur Forced Labor Prevention Act Entity List (15.01.2025) Official register or notice
Checked against the official source on 25 Sep 2026 · Direct link
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14 Jan 2025 AFCO (Tochtergesellschaft der Zep Inc.)Zep subsidiary AFCO: $161,310 proposed after nitrogen dioxide release €157,452
In July 2024, nitrogen dioxide above the exposure limit was released during chemical processing at the plant of Zep subsidiary AFCO in Chambersburg (Pennsylvania); twelve employees were examined in hospital and two were admitted. The U.S. Occupational Safety and Health Administration (OSHA) criticised the lack of an emergency action plan, deficient respiratory protection and hazard communication programmes and a delayed evacuation, and proposed $161,310 (including one repeat violation).
In the event of a chemical release, a rehearsed emergency and evacuation plan determines how many employees come to harm.
Responding to gas releases and evacuation
- Authority / court
- U.S. Department of Labor – Occupational Safety and Health Administration (OSHA)
- Area of law
- Health and safety and employment law · Workplace safety and accidents
- Legal basis
- 29 CFR 1910.120, 1910.134, 1910.1200
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Chemicals and pharmaceuticals
- Repeat case
- yes
- Published
- 14 Jan 2025
Original amount 161,310 USD, converted at the ECB reference rate of 14 Jan 2025.
Checked against the official source on 25 Sep 2026 · Direct link
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13 Jan 2025 BMO Capital Markets Corp.BMO Capital Markets: 40.7 million USD – inadequate supervision of bond desk €39.9m
From December 2020 to May 2023, staff on the agency CMO bond desk sold mortgage-backed bonds worth around 3 billion USD using misleading metrics; the broker-dealer’s supervisory procedures contained no requirements for the structuring and sale of these bonds. BMO paid 19,417,908 USD in disgorgement, 2,241,507 USD in interest and a civil penalty of 19 million USD.
Tailor supervisory procedures to the actual products and sales practices of each desk – generic policies are not enough.
- Authority / court
- U.S. Securities and Exchange Commission (SEC)
- Area of law
- Capital markets and financial supervision · Organisational requirements
- Legal basis
- Securities Exchange Act of 1934, Section 15(b)(4)(E) (Failure to supervise)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Financial services and insurance
- Employees
- 10,000 or more
Original amount 40,659,415 USD, converted at the ECB reference rate of 13 Jan 2025.
- SEC Charges BMO Capital Markets with Failing to Supervise Agency Bond Desk (13.01.2025) Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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7 Jan 2025 XCL Resources Holdings LLC, Verdun Oil Company II LLC, EP Energy LLCFTC: record penalty of 5.6 million USD for gun-jumping in oil producer acquisition €5.39m
During the HSR waiting period for the 1.4 billion USD acquisition of EP Energy, XCL and Verdun already took control of day-to-day operations: they halted drilling projects, managed customer contracts in Utah and coordinated prices in Texas (94 days). In a settlement filed by the DOJ on behalf of the FTC, the companies agreed to a civil penalty of 5.6 million USD – the highest ever for gun-jumping in the US; court approval under the Tunney Act was still pending at the time of publication.
Until clearance, the buyer must not exert any influence on the target company's operations – integration teams need clear gun-jumping rules.
Standstill obligation before clearance (gun-jumping) in integration planning
- Authority / court
- Federal Trade Commission (Klage durch das U.S. Department of Justice)
- Area of law
- Competition law · Merger control
- Legal basis
- Hart-Scott-Rodino Act
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Energy and utilities
- Published
- 7 Jan 2025
Original amount 5,600,000 USD, converted at the ECB reference rate of 7 Jan 2025.
- Oil Companies to Pay Record FTC Gun-Jumping Fine for Antitrust Law Violation Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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3 Jan 2025 GGL Projects, Inc. (Sitejabber)Sitejabber: review platform counted reviews before goods were received Order
According to the FTC, the AI-powered review platform collected star ratings for its business customers at the time of purchase, before customers had received the product or service, thereby inflating average ratings and review counts, including in search engine results. The FTC issued a final settlement order prohibiting such misrepresentations.
Ratings submitted before use must not be included in averages as experience-based reviews.
- Authority / court
- Federal Trade Commission (FTC)
- Area of law
- Consumer protection and online retail · Fake reviews
- Legal basis
- Section 5 FTC Act
- Action
- Order
- Status of proceedings
- final
- Sector
- Media and online platforms
- Published
- 3 Jan 2025
- FTC Approves Final Order against Sitejabber Press release of an authority
- FTC Case: Sitejabber (In the Matter of GGL Projects, Inc.) Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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19 Dec 2024 AAR Corp.Aviation services provider AAR pays 55.6 million USD for bribery in Nepal and South Africa €53.5m
Through an agent and a joint venture partner, AAR paid sham commissions to public officials in order to secure the sale of two Airbus A330s to Nepal Airlines and maintenance services for South African Airways Technical. SEC: 23,451,100 USD in disgorgement and 5,785,524 USD in interest; DOJ criminal penalty of 26,363,029 USD under a Non-Prosecution Agreement.
State-owned airlines are public contracting entities – scrutinise commissions to intermediaries in aircraft transactions rigorously.
Agents and joint venture partners in transactions with state-owned airlines
- Authority / court
- U.S. Securities and Exchange Commission (SEC); U.S. Department of Justice
- Area of law
- Bribery and corruption · Bribery of public officials
- Legal basis
- FCPA (Anti-Bestechung, Buchführung, interne Kontrollen); Non-Prosecution Agreement
- Action
- Fine
- Status of proceedings
- final
- Sector
- Transport, logistics and shipping
- Employees
- 1,000 to 9,999
- Culpability
- intentional
- Mitigating circumstances
- Disclosure following press reports, cooperation (forensics, translations, witnesses) and remedial measures.
- Liability of senior managers
- A former senior employee of an AAR subsidiary, Deepak Sharma (named in the SEC order), was involved.
- Published
- 19 Dec 2024
Original amount 55,599,653 USD, converted at the ECB reference rate of 19 Dec 2024.
- SEC Order In the Matter of AAR Corp., Release No. 101987 (19.12.2024) Decision of an authority
- DOJ Criminal Division: Non-Prosecution Agreement Re: AAR Corp. (19.12.2024) Decision of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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16 Dec 2024 Becton, Dickinson and Company (BD)Becton Dickinson: risks of Alaris infusion pump concealed – 175 million USD €166.7m
The medical technology manufacturer misled investors about regulatory risks of the Alaris infusion pump, which had more than 25 software defects, and did not record the remediation costs, as a result of which operating income in the fourth quarter of 2019 was overstated by 82 %. BD is paying 175 million USD and must appoint an independent compliance consultant.
Product and approval problems are capital market issues: quality and regulatory affairs departments must be involved in the disclosure process.
- Authority / court
- U.S. Securities and Exchange Commission (SEC)
- Area of law
- Capital markets and financial supervision · Disclosure and reporting obligations
- Legal basis
- Antifraud-, Reporting-, Buchführungs-, interne Kontroll- und Disclosure-Controls-Vorschriften der US-Wertpapiergesetze
- Action
- Fine
- Status of proceedings
- final
- Sector
- Healthcare
Original amount 175,000,000 USD, converted at the ECB reference rate of 16 Dec 2024.
- Becton Dickinson to Pay $175 Million for Misleading Investors About Alaris Infusion Pump Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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13 Dec 2024 C.H. Robinson International, Inc.C.H. Robinson: foreign subsidiaries transported Iranian and Cuban goods €244,999
From November 2018 to February 2022, five foreign subsidiaries of the logistics group acquired through takeovers brokered or transported a total of 82 shipments involving Iranian or Cuban goods or an Iranian airline. The main cause was that their booking systems had not yet been integrated into the group's screening processes; the US Treasury's Office of Foreign Assets Control (OFAC) considered the case non-egregious and voluntarily self-disclosed.
Connect acquired freight forwarders to central screening quickly; until then, interim controls on origin and carrier are needed.
Integrating acquired companies into sanctions screening
- Authority / court
- U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC)
- Area of law
- Sanctions and export control · Breaches of sanctions and embargoes
- Legal basis
- Iranian Transactions and Sanctions Regulations; Cuban Assets Control Regulations
- Action
- Fine
- Status of proceedings
- final
- Sector
- Transport, logistics and shipping
- Employees
- 10,000 or more
- Culpability
- negligent
- Repeat case
- no
- Mitigating circumstances
- Voluntary self-disclosure, no prior violations, swift remediation
- Published
- 13 Dec 2024
Original amount 257,690 USD, converted at the ECB reference rate of 13 Dec 2024.
- OFAC Enforcement Release: C.H. Robinson International Inc. Settles with OFAC for $257,690 (13.12.2024) Decision of an authority
- OFAC – 2024 Enforcement Information Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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22 Nov 2024 United Parcel Service Inc. (UPS)UPS: goodwill of UPS Freight division incorrectly valued – 45 million USD €43.2m
UPS based the valuation of UPS Freight on a consultant's appraisal of around 2 billion USD, although its own analyses had arrived at only about 650 million USD, and did not record a required goodwill impairment. UPS is paying 45 million USD and must introduce training for certain executives, board members and employees and engage an independent compliance consultant.
Valuation reports are only as good as the information given to the valuers – internal findings must feed into impairment tests.
- Authority / court
- U.S. Securities and Exchange Commission (SEC)
- Area of law
- Capital markets and financial supervision · Disclosure and reporting obligations
- Legal basis
- Section 17(a)(2),(3) Securities Act; Reporting-, Buchführungs-, interne Kontroll- und Disclosure-Controls-Vorschriften des Exchange Act
- Action
- Fine
- Status of proceedings
- final
- Sector
- Transport, logistics and shipping
Original amount 45,000,000 USD, converted at the ECB reference rate of 22 Nov 2024.
- UPS to Pay $45 Million Penalty for Improperly Valuing Business Unit Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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22 Nov 2024 Jindal Tubular USA LLCPipe mill Jindal Tubular: $442,815 settlement after fatal pipe collapse €425,293
In January 2024, insecurely stacked steel pipes weighing around 900 kg fell at the plant in Bay Saint Louis (Mississippi); a 25-year-old died and a 20-year-old lost both legs. In a settlement with the U.S. Occupational Safety and Health Administration (OSHA), the manufacturer of large steel pipes is paying $442,815 and must implement external safety consultants, monthly audits, safety professionals on every shift and three years of accident reporting; there had been 46 OSHA citations in five years.
Storage of heavy steel products requires binding stacking rules and exclusion zones – and repeated citations lead to far-reaching conditions.
- Authority / court
- U.S. Department of Labor – Occupational Safety and Health Administration (OSHA)
- Area of law
- Health and safety and employment law · Workplace safety and accidents
- Legal basis
- Occupational Safety and Health Act of 1970; 29 CFR 1910 (Maschinenschutz, Absturzsicherung, brennbarer Staub u. a.)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Steel and metals
- Employees
- 250 to 999
- Repeat case
- yes
- Published
- 22 Nov 2024
Original amount 442,815 USD, converted at the ECB reference rate of 22 Nov 2024.
Checked against the official source on 25 Sep 2026 · Direct link
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19 Nov 2024 Valenti's Bakery LLCNew Jersey bakery: $385,221 because deficiencies remained after finger amputation €364,172
Following the partial amputation of two fingers on an automatic blade, the U.S. Occupational Safety and Health Administration (OSHA) had inspected the bakery in Paterson in June 2023; at the follow-up inspection in May 2024, lockout/tagout procedures were still missing, and in addition exit routes were blocked and fall edges unprotected. Proposed: $385,221 (including failure to abate, 2 wilful and 1 repeat violation).
Follow-up inspections are the rule – companies that do not remedy cited deficiencies must expect additional penalties for failure to abate.
- Authority / court
- U.S. Department of Labor – Occupational Safety and Health Administration (OSHA)
- Area of law
- Health and safety and employment law · Workplace safety and accidents
- Legal basis
- 29 CFR 1910.147 (Lockout/Tagout), 1910.37 (Fluchtwege), 1910.212 (Maschinenschutz)
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Food and agriculture
- Culpability
- intentional
- Repeat case
- yes
- Published
- 19 Nov 2024
Original amount 385,221 USD, converted at the ECB reference rate of 19 Nov 2024.
- Department of Labor fines New Jersey bakery $385K after inspectors find workers still exposed to safety hazards (OSHA) Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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8 Nov 2024 Invesco Advisers, Inc.Invesco Advisers: 17.5 million USD for inflated ESG integration percentages €16.2m
From 2020 to 2022, Invesco told clients that 70 to 94 per cent of the parent company's assets under management were ‘ESG integrated’, but counted passive ETFs that did not take ESG into account and had no written definition of ESG integration. The U.S. Securities and Exchange Commission (SEC) imposed 17.5 million USD, a censure and a cease-and-desist order.
Sustainability metrics used in sales need a written definition and a traceable calculation.
Verifiable metrics in ESG marketing
- Authority / court
- U.S. Securities and Exchange Commission (SEC)
- Area of law
- Environment and sustainability · Misleading environmental and sustainability claims
- Legal basis
- Investment Advisers Act of 1940
- Action
- Fine
- Status of proceedings
- final
- Sector
- Financial services and insurance
- Culpability
- intentional
- Published
- 8 Nov 2024
Original amount 17,500,000 USD, converted at the ECB reference rate of 8 Nov 2024.
- SEC Charges Invesco Advisers for Making Misleading Statements About Supposed Investment Considerations Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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6 Nov 2024 595 Construction LLCIllinois framing contractor: $287,465 for repeatedly unprotected work at height €268,784
In May 2024, inspectors saw carpenters of the Crystal Lake company working on residential buildings in Elburn at heights of over 6 feet without fall protection three times within one month; training records and forklift certifications were also missing, and rigging equipment was damaged. The company had already been cited in 2022 and 2023. Proposed: $287,465.
Training records are mandatory, but only daily checks on site prevent falls.
Fall protection and hazard recognition on construction sites
Missing or inadequate training played a role in the decision.
- Authority / court
- U.S. Department of Labor – Occupational Safety and Health Administration (OSHA)
- Area of law
- Health and safety and employment law · Workplace safety and accidents
- Legal basis
- 29 CFR 1926 Subpart M (Fall Protection) u. a.
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Construction and real estate
- Culpability
- intentional
- Repeat case
- yes
- Published
- 6 Nov 2024
Original amount 287,465 USD, converted at the ECB reference rate of 6 Nov 2024.
Checked against the official source on 25 Sep 2026 · Direct link
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22 Oct 2024 Unisys Corp.SEC: $4 million against Unisys for downplaying cyber incidents after SolarWinds €3.7m
In mandatory disclosures, Unisys presented cyber risks as hypothetical, although it had suffered two intrusions with data exfiltration connected with the SolarWinds compromise. On the same day, the US Securities and Exchange Commission (SEC) also imposed penalties on Avaya ($1 million), Check Point ($995,000) and Mimecast ($990,000).
Do not describe cyber incidents that have occurred as a mere risk in investor information – disclosure processes must involve IT security.
- Authority / court
- U.S. Securities and Exchange Commission (SEC)
- Area of law
- Capital markets and financial supervision · Disclosure and reporting obligations
- Legal basis
- Securities Act of 1933, Securities Exchange Act of 1934 (inkl. Disclosure Controls)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Telecoms, IT and software
- Culpability
- negligent
- Mitigating circumstances
- Cooperation in the proceedings and improvement of cybersecurity controls.
- Published
- 22 Oct 2024
Original amount 4,000,000 USD, converted at the ECB reference rate of 22 Oct 2024.
- SEC Charges Four Companies With Misleading Cyber Disclosures Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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22 Oct 2024 Sahara Dunes Casino, LP (Lake Elsinore Hotel and Casino)FinCEN: 900,000 USD against Lake Elsinore card club over missing reports €831,716
The US Financial Crimes Enforcement Network (FinCEN) imposed 900,000 USD on the Californian card club, which admitted wilful infringements over more than four and a half years: no effective AML programme, missing currency transaction reports (CTR) and suspicious activity reports (SAR), and record-keeping deficiencies. The infringements stemmed from decisions by management.
Even small casinos and card clubs must file currency transaction reports and suspicious activity reports without gaps – management decisions to the contrary are considered wilful.
Currency transaction and suspicious activity reports in gambling operations
- Authority / court
- Financial Crimes Enforcement Network (FinCEN)
- Area of law
- Money laundering and terrorist financing · Suspicious activity reports
- Legal basis
- Bank Secrecy Act (BSA) und Durchführungsbestimmungen
- Action
- Fine
- Status of proceedings
- final
- Sector
- Other
- Culpability
- intentional
- Liability of senior managers
- According to FinCEN, the infringements were based on decisions by management
- Published
- 23 Oct 2024
Original amount 900,000 USD, converted at the ECB reference rate of 22 Oct 2024.
- FinCEN Assesses $900,000 Civil Money Penalty Against Lake Elsinore Hotel and Casino for Violations of the Bank Secrecy Act Press release of an authority
- FinCEN Consent Order – Sahara Dunes Casino, LP d/b/a Lake Elsinore Hotel and Casino (Number 2024-03) Decision of an authority
- FinCEN Enforcement Actions Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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16 Oct 2024 RTX Corporation (Raytheon Company)RTX (Raytheon) pays around 391 million USD for bribing a Qatari military official €338.4m
From 2011 to 2017, Raytheon paid almost 2 million USD via sham subcontracts to Qatari military and other public officials and more than 30 million USD to an agent from the ruling family. SEC order: disgorgement of 37,400,090 USD, interest of 11,786,208 USD and a penalty of 75 million USD (of which 22.5 million USD was credited against the DOJ payment); under the DPA with the DOJ, 267,096,068 USD (230.4 million penalty, 36,696,068 forfeiture) is attributable to the FCPA part, combined with an Arms Export Control Act violation and a three-year monitorship. Total without double counting: 368,782,366 USD.
Subcontracts without verifiable services are a classic vehicle for bribes – defence exporters must also disclose payment flows to export control authorities.
Sham subcontracts and agents in defence transactions
- Authority / court
- U.S. Securities and Exchange Commission (SEC); U.S. Department of Justice
- Area of law
- Bribery and corruption · Bribery of public officials
- Legal basis
- FCPA (Anti-Bestechung, Buchführung, interne Kontrollen, Sections 30A, 13(b)(2)(A)/(B) Exchange Act); Arms Export Control Act; DPA
- Action
- Fine
- Status of proceedings
- final
- Sector
- Defence and security
- Employees
- 10,000 or more
- Culpability
- intentional
- Published
- 16 Oct 2024
Original amount 368,782,366 USD, converted at the ECB reference rate of 16 Oct 2024.
- SEC Order In the Matter of RTX Corporation, Release No. 101353 (16.10.2024) Decision of an authority
- SEC Enforcement Actions: FCPA Cases Enforcement database of an authority
- DOJ Criminal Division: U.S. v. Raytheon Company, Docket No. 24-CR-399 (RER) Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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11 Oct 2024 Moog Inc.Moog: SEC order over bribery of Indian public officials by a subsidiary €1.54m
From 2020 to 2022, employees of the Indian subsidiary of the aerospace and defence supplier bribed Indian public officials via agents and distributors, among other things to tailor tenders in Moog's favour; the payments were booked as business expenses. Payment of 504,926 USD in disgorgement, 78,889 USD in interest and a penalty of 1.1 million USD.
Even small foreign subsidiaries need effective controls over payments to distributors and agents – otherwise the listed parent company is liable under the books-and-records provisions.
Influencing tender conditions via distributors
- Authority / court
- U.S. Securities and Exchange Commission (SEC)
- Area of law
- Bribery and corruption · Bribery of public officials
- Legal basis
- FCPA Buchführungs- und interne Kontrollvorschriften (Sections 13(b)(2)(A)/(B) Exchange Act)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Manufacturing and mechanical engineering
- Culpability
- intentional
- Mitigating circumstances
- Cooperation (sharing of internal investigation findings) and remediation, including termination of employees and third parties.
- Published
- 11 Oct 2024
Original amount 1,683,815 USD, converted at the ECB reference rate of 11 Oct 2024.
- SEC Order In the Matter of Moog Inc., Release No. 101307 (11.10.2024) Decision of an authority
- SEC Enforcement Actions: FCPA Cases Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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10 Oct 2024 The Toronto-Dominion BankFederal Reserve: 123.5 million USD against Toronto-Dominion Bank over AML oversight failure €113m
The Board of Governors of the Federal Reserve System imposed 123.5 million USD on the Canadian parent company because it neglected risk management and oversight of its US retail business, so that a US subsidiary was used to launder hundreds of millions of dollars. TD must move the AML programme to the US and commission an independent review of the board and management; the sanctions of all authorities involved (DOJ, FinCEN, OCC) add up to around 3.09 billion USD.
Parent companies are responsible for effective AML oversight of their foreign business – failures there can lead to sanctions running into billions.
- Authority / court
- Board of Governors of the Federal Reserve System
- Area of law
- Money laundering and terrorist financing · Internal controls
- Legal basis
- US-Anti-Geldwäschegesetze (laut Federal Reserve)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Financial services and insurance
- Employees
- 10,000 or more
- Liability of senior managers
- Independent review of board and management ordered
- Published
- 10 Oct 2024
Original amount 123,500,000 USD, converted at the ECB reference rate of 10 Oct 2024.
- Federal Reserve Board fines Toronto-Dominion Bank $123.5 million for violations related to anti-money laundering laws Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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1 Oct 2024 Tradition SEF LLCTradition SEF: 875,000 USD – emergency and security tests not brought before the board €789,284
The swap trading platform did not fully inform its board of the results of emergency, technology risk and penetration tests, did not regularly test its business continuity and disaster recovery capabilities and had no adequate risk management. It also failed to produce documents requested during an examination on time despite extensions of deadlines; the Commodity Futures Trading Commission (CFTC) imposed 875,000 USD.
Contingency plans only count if they are tested regularly and the results are noted by the entire governing body.
- Authority / court
- Commodity Futures Trading Commission (CFTC)
- Area of law
- Information security and cyber · Critical infrastructure
- Legal basis
- Commodity Exchange Act; CFTC-Regeln zu System Safeguards für Swap Execution Facilities
- Action
- Fine
- Status of proceedings
- final
- Sector
- Financial services and insurance
Original amount 875,000 USD, converted at the ECB reference rate of 1 Oct 2024.
- CFTC Orders Tradition SEF LLC to Pay $875,000 for System Safeguards Violations … (01.10.2024) Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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27 Sep 2024 Invitation Homes Inc.Invitation Homes pays 48 million USD in FTC settlement over hidden mandatory fees €43m
According to the FTC, the largest US landlord of single-family homes advertised monthly rents without mandatory additional fees (for example for smart home technology or utility management), which could add up to more than 1,700 USD a year and only appeared in the lease; further allegations concerned withheld security deposits and evictions. Under the settlement, Invitation Homes is paying 48 million USD for refunds and must include mandatory fees in the advertised price.
Unavoidable fees belong in the first advertised price, not in the contract documents.
- Authority / court
- Federal Trade Commission (FTC)
- Area of law
- Consumer protection and online retail · Misleading advertising and pricing
- Legal basis
- Section 5 FTC Act
- Action
- Disgorgement of profits
- Status of proceedings
- final
- Sector
- Construction and real estate
- Published
- 24 Sep 2024
Original amount 48,000,000 USD, converted at the ECB reference rate of 27 Sep 2024.
- FTC Takes Action Against Invitation Homes for Deceiving Renters, Charging Junk Fees Press release of an authority
- FTC v. Invitation Homes Inc. – Stipulated Order entered by the Court (N.D. Ga., 27.09.2024) Court decision
Checked against the official source on 25 Sep 2026 · Direct link
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26 Sep 2024 GQG Partners LLCSEC: GQG Partners pays 500,000 US dollars over NDAs and severance agreement €448,229
The asset manager had twelve job applicants sign NDAs that prohibited voluntary reports to authorities, and, in a settlement agreement, required a former employee who had announced a report to the SEC to confirm that he had not initiated any investigation and to withdraw statements already made. The U.S. Securities and Exchange Commission (SEC) took cooperation and remediation into account and imposed 500,000 US dollars.
Companies concluding a settlement with a whistleblower may require neither the withdrawal of nor a waiver of reports to authorities.
Handling announced reports to authorities in separation negotiations
- Authority / court
- U.S. Securities and Exchange Commission
- Area of law
- Whistleblower protection · Retaliation against whistleblowers
- Legal basis
- Securities Exchange Act of 1934, Rule 21F-17(a); Investment Advisers Act Section 203(e)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Financial services and insurance
- Employees
- 50 to 249
- Mitigating circumstances
- Cooperation with the SEC and prompt remedial measures
- Published
- 26 Sep 2024
Original amount 500,000 USD, converted at the ECB reference rate of 26 Sep 2024.
- In the Matter of GQG Partners LLC, Release No. 34-101200 Decision of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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16 Sep 2024 COBB Tuning Products, LLCCOBB Tuning: 2.914 million USD for over 81,000 tuners that disable emission controls €2.62m
Since 2015, the Austin-based manufacturer has sold more than 81,000 tuners that deactivate emission controls, as well as 8,400 exhaust pipes with fewer or weaker catalytic converters. The proposed settlement with the U.S. Environmental Protection Agency (EPA) and the U.S. Department of Justice (subject to court approval) provides for a civil penalty of 2,914,000 USD in four instalments, as well as a ban on defeat devices, removal of the ‘delete’ functions, information for dealers and customers, buy-back and destruction of such devices held by employees, and Clean Air Act training for the workforce.
Tuning products that circumvent emission controls are prohibited even as ‘racing parts’ – product approvals require an emissions review.
Emissions law for aftermarket products
Missing or inadequate training played a role in the decision.
- Authority / court
- U.S. Environmental Protection Agency / U.S. Department of Justice (U.S. District Court, Western District of Texas)
- Area of law
- Environment and sustainability · Emissions and permits
- Legal basis
- Clean Air Act § 203(a)(3)(B), 42 U.S.C. § 7522(a)(3)(B)
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Automotive
- Mitigating circumstances
- Amount of the penalty based on demonstrated limited ability to pay; payment in instalments.
Original amount 2,914,000 USD, converted at the ECB reference rate of 16 Sep 2024.
- COBB Tuning Products, LLC Clean Air Act Settlement Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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16 Sep 2024 Fünf Wingstop-Filialgesellschaften in Kern County (Inhaber Clinton Lewis)Wingstop franchisee: 1.7 million USD – overtime evaded by splitting up companies €1.53m
The franchisee ran five Wingstop outlets in Bakersfield as separate companies and deployed employees at several locations on the same day. As a result, they lost out on overtime premiums after eight hours a day or 40 hours a week, premiums for missed meal breaks, paid travel time and the higher minimum wage for larger employers; the settlement of 1.7 million USD concerns around 550 employees.
Working time is added up across all locations of the same employer – splitting into separate companies does not protect against overtime obligations.
- Authority / court
- California Labor Commissioner's Office (Division of Labor Standards Enforcement)
- Area of law
- Health and safety and employment law · Working time
- Legal basis
- California Labor Code (Overtime, Meal Periods, Mindestlohn)
- Action
- Other
- Status of proceedings
- final
- Sector
- Food and agriculture
- Culpability
- intentional
- Liability of senior managers
- Owner Clinton Lewis personally responsible.
Original amount 1,700,000 USD, converted at the ECB reference rate of 16 Sep 2024.
- California DIR News Release 2024-73: California Labor Commissioner’s Office reaches $1.7 million settlement in Wingstop wage theft case (16.09.2024) Press release of an authority
- California DIR News Release 2023-68: California Labor Commissioner Cites Five Winstop Fast Food Restaurants and Their Owner More Than $3 Million (28.09.2023) Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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10 Sep 2024 Rudy's Performance Parts, Inc.Rudy's Performance Parts: 10 million USD in criminal and civil penalties for defeat devices €9.07m
From 2014 to 2019, the North Carolina company and its CEO Aaron Rudolf manufactured, sold or installed over 250,000 parts for Ford, GM and Dodge diesel pickups in order to remove emission controls – according to the U.S. Environmental Protection Agency (EPA), producing as much in emissions as more than 11 million additional vehicles. A total of 10 million USD: a civil penalty of 7 million USD in instalments (settlement subject to court approval), a criminal fine of 2.4 million USD against the company together with three years' probation, and a fine of 600,000 USD against the CEO.
Those who run emissions tampering as a business model are liable under civil and criminal law – all the way up to management.
- Authority / court
- U.S. Environmental Protection Agency / U.S. Department of Justice
- Area of law
- Environment and sustainability · Emissions and permits
- Legal basis
- Clean Air Act § 203(a)(3)
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Automotive
- Culpability
- intentional
- Mitigating circumstances
- Payment in instalments because of demonstrated limited ability to pay.
- Liability of senior managers
- CEO Aaron Rudolf: three years' probation and a fine of 600,000 USD in the criminal proceedings; personally a party to the civil settlement.
Original amount 10,000,000 USD, converted at the ECB reference rate of 10 Sep 2024.
- Rudy's Performance Parts, Inc. and Aaron Rudolf Clean Air Act Settlement Information Sheet Press release of an authority
- EPA: North Carolina auto parts seller and its owner to pay $10M for making, selling and installing defeat devices Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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10 Sep 2024 Deere & CompanyDeere pays 9.9 million USD: Wirtgen Thailand bribed the air force and the highways authority €9m
From 2017 to 2020, the acquired subsidiary Wirtgen Thailand provided public officials, including officials of the Royal Thai Air Force and the Department of Highways, with cash, sham consultancy fees, luxurious "factory visit trips", meals and entertainment, and also engaged in commercial bribery. Deere is paying 4,343,401 USD in disgorgement, 1,086,954 USD in interest and a penalty of 4.5 million USD.
After acquisitions, integrate subsidiaries swiftly into the compliance programme and controls – otherwise old practices such as luxury trips for customers live on.
Travel, hospitality and entertainment for public officials
- Authority / court
- U.S. Securities and Exchange Commission (SEC)
- Area of law
- Bribery and corruption · Gifts, hospitality and benefits
- Legal basis
- FCPA Buchführungs- und interne Kontrollvorschriften (Sections 13(b)(2)(A)/(B) Exchange Act)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Manufacturing and mechanical engineering
- Employees
- 10,000 or more
- Culpability
- intentional
- Liability of senior managers
- According to the SEC, senior regional managers who have since left the company were involved (not named).
- Published
- 10 Sep 2024
Original amount 9,930,355 USD, converted at the ECB reference rate of 10 Sep 2024.
- SEC Order In the Matter of Deere & Company, Release No. 100984 (10.09.2024) Decision of an authority
- SEC Enforcement Actions: FCPA Cases Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link