Who was sanctioned, and for what?

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.

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.

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

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 a further settling party are jointly paying 100 million USD for refunds; the order is not yet final.

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

Measures against individuals are not reported here.

Published

17 Sep 2026

Original amount 100,000,000 USD, converted at the ECB reference rate of 17 Sep 2026.

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

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.

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.

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

The nationwide wine and spirits distributor headquartered in Florida entered into a non-prosecution agreement and pays USD 12.5 million. It admitted that executives and employees had for years provided employees of alcohol retailers, including grocery chains in California, with cash, prepaid gift cards, flights, golf trips, resort stays and luxury goods to influence the purchase and placement of its products, concealing this through third-party vendors and false invoices. The authority allegedly made the findings set out here; this account is not based on a final judgment.

Authority / court

U.S. Attorney's Office, Northern District of California (U.S. Department of Justice)

Area of law

Bribery and corruption · Commercial bribery

Action

Other

Status of proceedings

final

Sector

Retail and e-commerce

Liability of senior managers

According to the announcement, several California-based executives, including vice presidents, were directly involved.

Published

10 Sep 2026

Original amount 12,500,000 USD, converted at the ECB reference rate of 10 Sep 2026.

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

On board the MSC Samira III, oily bilge water was pumped overboard via the sewage tank, bypassing the oily water separator, in 2024/2025; the oil content monitoring was manipulated and the oil record book, which was presented to the Coast Guard in Philadelphia, was falsified. 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.

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

Published

28 Aug 2026

Original amount 1,750,000 USD, converted at the ECB reference rate of 28 Aug 2026.

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

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).

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.

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

Despite promising no hidden fees, the travel app, according to the FTC, charged tips and fees for a VIP support service without consent because they were hidden and pre-selected, and misled users about total prices and the benefits of VIP support and price freezing. The court order against the Canadian Hopper Inc. and its US subsidiary sets 35 million USD, payable in twelve instalments. The authority allegedly made the findings set out here; this account is not based on a final judgment.

Authority / court

Federal Trade Commission (FTC)

Area of law

Consumer protection and online retail · Misleading advertising and pricing

Legal basis

Section 5 FTC Act; Rule on Unfair or Deceptive Fees (16 C.F.R. Part 464)

Action

Disgorgement of profits

Status of proceedings

final

Sector

Media and online platforms

Published

2 Jul 2026

Original amount 35,000,000 USD, converted at the ECB reference rate of 20 Aug 2026.

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

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.

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

A jury found Sioux Erosion Control 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; the decision is not final.

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

Measures against individuals are not reported here.

Published

20 Aug 2026

Checked against the official source on 28 Sep 2026 · Version 4 · Direct link

The neurotechnology company from Dallas, described by the Bureau of Industry and Security (BIS, the export control agency of the US Department of Commerce) as small, delivered neural data acquisition systems (“OmniPlex”) and accessories worth around 179,000 USD on eight occasions in 2022/23 via its Asian distributor to the Chinese Academy of Military Medical Sciences, which has been on the Entity List (the US export control list of restricted parties) since December 2021. The penalty of 1.7 million USD is suspended for five years and then waived, provided that Plexon submits an external audit of its export compliance programme on time and commits no further violations; a five-year denial of export privileges is likewise suspended, and Plexon must also provide export control training.

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, 15 C.F.R. § 764.2(a), § 744.11

Action

Fine

Status of proceedings

final

Sector

Healthcare

Mitigating circumstances

Penalty and denial of export privileges fully suspended for five years, conditional on an external export control audit.

Published

14 Aug 2026

Original amount 1,700,000 USD, converted at the ECB reference rate of 14 Aug 2026.

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

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.

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

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

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.

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.

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

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.

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

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

The Taiwanese LED manufacturer and its Texas subsidiary allegedly transshipped LEDs made in China via Taiwan from 2018 to 2022 and declared them to US customs as being of Taiwanese origin in order to avoid Section 301 tariffs (US punitive tariffs on Chinese goods); in addition, Chinese and Taiwanese chips were not kept separate in production until 2025. The settlement of 5.15 million USD resolves a whistleblower lawsuit brought by a former employee, who receives around 876,000 USD.

Authority / court

U.S. Attorney’s Office District of Maryland (Department of Justice) mit U.S. Customs and Border Protection

Area of law

Sanctions and export control · Customs

Legal basis

False Claims Act; Tariff Act of 1930 (Vergleich; Haftung nicht festgestellt)

Action

Other

Status of proceedings

final

Sector

Manufacturing and mechanical engineering

Published

5 Aug 2026

Original amount 5,150,000 USD, converted at the ECB reference rate of 5 Aug 2026.

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

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.

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.

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

The DDTC settled with BAE Systems, Inc. for a civil penalty of USD 36 million. The allegations concerned unauthorised exports and retransfers of defence articles to several countries, in one case to the People's Republic of China, the unauthorised furnishing of defence services and breaches of authorisation provisos. USD 18 million is suspended for approved compliance measures and USD 18 million is payable in three instalments; the agreement requires, among other things, an external compliance audit. The authority allegedly made the findings set out here; this account is not based on a final judgment.

Authority / court

U.S. Department of State, Directorate of Defense Trade Controls (DDTC)

Area of law

Sanctions and export control · Export control and dual-use goods

Legal basis

Arms Export Control Act § 38 (22 U.S.C. § 2778); ITAR, 22 C.F.R. Parts 120–130, insbesondere Part 127 und § 128.11

Action

Fine

Status of proceedings

final

Sector

Defence and security

Mitigating circumstances

The company reported the matters in voluntary disclosures and in response to a disclosure directed by the DDTC, and cooperated with the review.

Original amount 36,000,000 USD, converted at the ECB reference rate of 4 Aug 2026.

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

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.

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.

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

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.

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

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

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.

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

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

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.

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

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