Compliance Radar

Who was sanctioned, and for what?

Fines, court rulings and incidents from Europe, North America, Latin America, Asia-Pacific, Middle East and Africa: 2,207 cases from 44 jurisdictions, each with an official source and checked against that source before publication. Filter by country, area of law and sector. Click a chart to drill down one level.

USA Clear all filters
319cases from 1 jurisdiction
€22.5bnTotal of monetary amounts (278 cases with an amount)
€4.75bnLargest single case: Purdue Pharma L.P.
€5.26mMedian per case with an amount

Click a bar to drill down one level.

When?

per year, by date of decision
Trend
PeriodCasesTotal
202217€1.85bn
202355€3.47bn
202482€3.42bn
202587€7.11bn
202678€6.67bn

319 cases

22 Sep 2026 OTC Link LLCOTC Link: 575,000 USD – security policies never completed despite examination findings USACritical infrastructure €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.

What organisations can take from it

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.

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

What organisations can take from it

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
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

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10 Sep 2026 Dompé U.S. Inc.Dompé U.S.: 32 million USD – Medicare patients’ co-payments covered via foundations USAGifts, hospitality and benefits €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.

What organisations can take from it

Benefits flowing to customers via foundations or other third parties remain benefits provided by the company – donations to patient assistance programmes require strict independence.

Relevance to training and awareness

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.

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

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10 Sep 2026 Southern Glazer’s Wine and Spirits, LLCSouthern Glazer’s: USD 12.5m over benefits to retailer employees USACommercial bribery €10.8m

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.

What organisations can take from it

Benefits to customers' employees are commercial bribery – marketing budgets run through third-party vendors need document and recipient checks.

Relevance to training and awareness

Benefits to buyers and employees of trade customers; concealment through third-party vendors and false invoices

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

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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 USAWaste and hazardous substances €1.5m

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.

What organisations can take from it

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.

Relevance to training and awareness

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
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

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24 Aug 2026 Container Manufacturing Ltd.Small US machinery supplier exported spare parts for can presses to Russia USAExport control and dual-use goods €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).

What organisations can take from it

Even small businesses with few employees must check tariff codes against Russia restrictions and treat deliveries via third countries as a warning sign.

Relevance to training and awareness

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.

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

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20 Aug 2026 Hopper (USA) Inc. und Hopper Inc.FTC: travel app Hopper pays 35 million USD over hidden and pre-selected fees USAMisleading advertising and pricing €30m

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.

What organisations can take from it

Paid add-ons must never be pre-selected or hidden in the booking flow.

Relevance to training and awareness

Pre-selected add-ons and fees in booking flows

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

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20 Aug 2026 IPMF LLC (NaturPak)NaturPak: $364,100 proposed after three deaths caused by bursting kettle lids USAWorkplace safety and accidents €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.

What organisations can take from it

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 USACartels and collusion –

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.

What organisations can take from it

Subcontractors in public road construction are also targeted by prosecutors.

Relevance to training and awareness

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
Measures against individuals are not reported here.
Published
20 Aug 2026

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

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14 Aug 2026 Plexon, Inc.Plexon: brain research recording systems to listed Chinese military medical academy – 1.7 million USD suspended USAExport control and dual-use goods €1.47m

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.

What organisations can take from it

Screen orders placed via distributors against the Entity List before production – research equipment can also end up with listed military institutions.

Relevance to training and awareness

Entity List screening for orders via distribution partners

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, 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

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14 Aug 2026 Henkel AG & Co. KGaAHenkel/Liquid Nails: court blocks takeover of Loctite’s main competitor USAMerger control 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.

What organisations can take from it

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

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 USABreaches of sanctions and embargoes €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.

What organisations can take from it

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.

Relevance to training and awareness

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.

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 USAGifts, hospitality and benefits 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.

What organisations can take from it

Invitations and gifts to decision-makers must not only be limited but also fully reported to transparency registers.

Relevance to training and awareness

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

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

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5 Aug 2026 Everlight Electronics Co., Ltd. und Everlight Americas, Inc.Everlight: 5.15 million USD – Chinese LEDs declared as Taiwanese via Taiwan USACustoms €4.46m

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.

What organisations can take from it

Where goods are routed through third countries, document their origin by manufacturing step – repackaging in Taiwan does not turn Chinese goods into Taiwanese ones.

Relevance to training and awareness

Rules of origin and origin of goods when transshipping via third countries

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

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5 Aug 2026 Order Express, Inc.NYDFS: $250,000 against money transmitter Order Express over cyber deficiencies USA, NYSecurity measures and risk management €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.

What organisations can take from it

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.

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

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4 Aug 2026 BAE Systems, Inc.DDTC: USD 36 million against BAE Systems for ITAR violations, including a China link USAExport control and dual-use goods €31.3m

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.

What organisations can take from it

Retransfers by recipients must be controlled contractually and organisationally just as strictly as one's own exports.

Relevance to training and awareness

ITAR compliance: retransfers, defence services and authorisation provisos

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

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3 Aug 2026 UBS Financial Services Inc.FinCEN: 125 million USD against UBS Financial Services as a repeat offender USAInternal controls €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.

What organisations can take from it

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.

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 USAForced and child labour 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.

What organisations can take from it

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

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 USAForced and child labour 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.

What organisations can take from it

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

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 USAForced and child labour 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.

What organisations can take from it

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

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

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31 Jul 2026 UBS Financial Services Inc.UBS Financial Services: 8 million USD over gaps in anti-money laundering monitoring USAOrganisational requirements €6.97m

The CFTC fined the futures commission merchant 8 million USD for failing to supervise diligently the configuration and operation of its anti-money laundering transaction monitoring. From January 2019 to June 2023, thousands of foreign currency wire transfers through retail customers' commodity accounts were insufficiently monitored or not monitored at all: first because of an incomplete manual report which UBS, contrary to commitments made in earlier proceedings in 2018, replaced only more than two years later, and then because of incorrectly fed data in the new automated system. FinCEN, the SEC and FINRA announced their own settlements with UBS Financial Services at the same time. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

Commitments made in earlier supervisory proceedings must be implemented on time, and new monitoring systems must be tested for complete data feeds before going live.

Authority / court
U.S. Commodity Futures Trading Commission (CFTC)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
CFTC Regulation 166.3 (17 C.F.R. § 166.3)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Repeat case
yes
Mitigating circumstances
The CFTC recognised the remediation described; according to the order, the core problems of the automated system had been fixed by the fourth quarter of 2022.
Published
3 Aug 2026

Original amount 8,000,000 USD, converted at the ECB reference rate of 31 Jul 2026.

Checked against the official source on 3 Oct 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 USACommercial bribery €31.7m

The Houston laboratory allegedly paid kickbacks and billed Medicare and Medicaid for medically unnecessary genetic tests. The settlements with the laboratory and other parties add up to 36.4 million USD (combined total); the laboratory is subject to a Corporate Integrity Agreement.

What organisations can take from it

Commission models for intermediaries who bring in orders or patients are a classic gateway for bribery.

Relevance to training and awareness

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
Measures against individuals are not reported here.

Original amount 36,400,000 USD, converted at the ECB reference rate of 30 Jul 2026.

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

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23 Jul 2026 Orchids Builders LLCFlorida roofer: OSHA proposes $349,754 over allegedly repeated lack of fall protection USAWorkplace safety and accidents €307,017

According to the U.S. Occupational Safety and Health Administration (OSHA), inspectors found on 21 January and 10 March 2026 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 citations for fall protection. OSHA proposed penalties of $349,754 (2 violations classified as wilful, 4 as repeat); the violations are alleged and may be contested.

What organisations can take from it

Companies that allow the same fall hazards to recur after earlier inspections risk classification as a repeat or wilful violation with substantially higher penalties.

Relevance to training and awareness

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 28 Sep 2026 · Version 2 · Direct link

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21 Jul 2026 1-800-Flowers.com, Inc.New York: 1-800-Flowers pays 375,000 USD over concealed subscription renewals USA, NYInformation duties in online retail €328,429

According to the Attorney General's office, the company sold an annual shipping subscription ("Celebrations Passport") whose terms between February 2021 and June 2022 appeared only in small print, in linked terms or in pop-up boxes; a post-purchase acknowledgement and a notice before automatic renewal were missing. In the Assurance of Discontinuance it undertakes to pay 375,000 USD in penalties, fees and costs, to refund subscribers and to change its subscription processes. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

Automatically renewing subscriptions need clear terms before purchase, a purchase acknowledgement and a reminder before renewal.

Relevance to training and awareness

Transparent subscription models with automatic renewal

Authority / court
Office of the New York State Attorney General
Area of law
Consumer protection and online retail · Information duties in online retail
Legal basis
New York General Business Law §§ 349, 527-a; Executive Law § 63(12); Restore Online Shoppers' Confidence Act (15 U.S.C. § 8403)
Action
Fine
Status of proceedings
final
Sector
Retail and e-commerce
Published
22 Jul 2026

Original amount 375,000 USD, converted at the ECB reference rate of 21 Jul 2026.

Checked against the official source on 3 Oct 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 USACommercial bribery €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.

What organisations can take from it

Free or discounted services are also benefits – like cash payments, they belong in the anti-corruption review.

Relevance to training and awareness

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.

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 USACommercial bribery €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.

What organisations can take from it

Discounts, payments or services to institutions that make purchasing decisions require a documented consideration at market value.

Relevance to training and awareness

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.

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 USABribery of public 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.

What organisations can take from it

Customs agents and freight forwarders are high-risk third parties: question conspicuous flat fees per shipment, even if they appear to be customary charges.

Relevance to training and awareness

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
Measures against individuals are not reported here.
Published
17 Jul 2026

Original amount 10,183,872 USD, converted at the ECB reference rate of 17 Jul 2026.

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

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16 Jul 2026 Swedbank AB (publ) (mit New York Branch)NYDFS: USD 50 million against Swedbank for withholding information USA, New YorkDisclosure and reporting obligations €43.6m

The NYDFS imposed a penalty of USD 50 million on Swedbank AB (publ) and its New York branch. In response to several requests by the regulator under section 37 of the New York Banking Law concerning links between its Baltic subsidiaries and the law firm Mossack Fonseca (Panama Papers) and the status of European investigations, the bank did not provide the requested information, in breach of section 125(3) of the New York Banking Law. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

Information requests from the regulator must be answered in full; withholding information is sanctioned in its own right.

Relevance to training and awareness

Complete and truthful disclosures to the regulator

Authority / court
New York State Department of Financial Services (NYDFS)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
New York Banking Law § 125(3) i. V. m. § 37; Sanktion nach Banking Law §§ 39, 44
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Liability of senior managers
According to the order, the bank has since, among other things, dismissed its then Chief Compliance Officer and its former CEO and parted ways with numerous other employees; the majority of the board has been replaced.
Published
16 Jul 2026

Original amount 50,000,000 USD, converted at the ECB reference rate of 16 Jul 2026.

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

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15 Jul 2026 New York Packaging II LLC (Redi-Bag USA)Redi-Bag USA: 7.3 million USD – “Made in China” marking on carrier bags concealed USACustoms €6.4m

The packaging supplier allegedly imported plastic carrier bags made in China via Hong Kong and declared them as goods from Hong Kong in order to evade anti-dumping duties of up to 77.57%. According to the US Department of Justice (DOJ), the company had employees cover up “Made in China” markings, concealed the origin from its customs broker and cancelled orders that were due to be inspected; the settlement of 7.3 million USD (a joint payment with a further settling party) resolves a whistleblower lawsuit.

What organisations can take from it

Never instruct staff to conceal origin markings – doing so turns a tariff issue into deliberate customs fraud; give employees a reporting channel for such instructions.

Relevance to training and awareness

Origin declarations and handling of origin markings in goods receipt

Authority / court
U.S. Department of Justice, Civil Division, und U.S. Attorney’s Office District of New Jersey
Area of law
Sanctions and export control · Customs
Legal basis
False Claims Act, 31 U.S.C. §§ 3729 ff. (Vergleich; Haftung nicht festgestellt)
Action
Other
Status of proceedings
final
Sector
Retail and e-commerce
Liability of senior managers
Measures against individuals are not reported here.
Published
15 Jul 2026

Original amount 7,300,000 USD, converted at the ECB reference rate of 15 Jul 2026.

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

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15 Jul 2026 Vanilla Chip LLC (TruHeight)TruHeight: FTC settlement over allegedly fake reviews for growth supplement USAFake reviews €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 a joint payment of 750,000 USD by the liable parties.

What organisations can take from it

Reviews by employees or reviews rewarded for positive star ratings are prohibited and, since 2024, subject to civil penalties.

Relevance to training and awareness

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
Measures against individuals are not reported here.
Published
15 Jul 2026

Original amount 750,000 USD, converted at the ECB reference rate of 15 Jul 2026.

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

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15 Jul 2026 FleetPride Inc.FleetPride: $264,380 after asphyxiation death during tank trailer inspection USAWorkplace safety and accidents €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).

What organisations can take from it

Tanks and vessels are confined spaces with a risk of asphyxiation – no one may enter without a permit, atmospheric testing and an attendant.

Relevance to training and awareness

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.

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

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26 Jun 2026 One Way Environmental Services LLC; Coastal Environmental Solutions Inc.; BWC Terminals LLCSulphuric acid spill in Channelview: USD 3.52m in OSHA penalties against three employers USAWorkplace safety and accidents €3.09m

After around one million gallons of sulphuric acid were released at the BWC Terminals site in Channelview (Texas) in December 2025, OSHA proposed penalties totalling 3,520,703 USD against three employers. Staffing contractor One Way Environmental Services accounts for 3,045,452 USD for 18 violations classed as wilful and egregious and five as serious, because it sent workers to the clean-up without adequate training, respirator fit tests and safety measures; the hazardous waste contractor Coastal Environmental Solutions faces 392,501 USD and BWC Terminals, which had mixed fresh and spent acid despite warnings, 82,750 USD. The authority allegedly made the findings set out here; this account is not based on a final judgment. The decision is not final.

What organisations can take from it

Companies that outsource clean-up after a chemical incident must check their contractors' training, respiratory protection and emergency planning.

Relevance to training and awareness

Health and safety during clean-up after chemical incidents

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
Occupational Safety and Health Act (u. a. Vorschriften zu Gefahrstoffeinsätzen und Notfallmaßnahmen sowie Atemschutz)
Action
Fine
Status of proceedings
not yet final
Sector
Other
Published
26 Jun 2026

Original amount 3,520,703 USD, converted at the ECB reference rate of 26 Jun 2026.

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

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26 Jun 2026 Netrios LP Ltd.; Red Acre Ltd.Netrios and Red Acre: 2.5 million USD for white-label leveraged trading with US retail customers USAOrganisational requirements €2.19m

The CFTC fined Netrios LP Ltd., incorporated in Saint Lucia, 1,750,000 USD and Maltese Red Acre Ltd. 750,000 USD, totalling 2,500,000 USD. From 2019 to September 2025, Netrios sold a white-label service (website, trading software, margin accounts, execution, back office) through which offshore platforms offered US retail customers who were not eligible contract participants leveraged forex, precious metals, crypto and equity transactions outside a registered exchange; Red Acre assisted with customer support and marketing. The SEC took parallel action over the same conduct. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

Technology and service providers share liability if their platform solution enables US retail customers to trade on leverage unlawfully outside registered exchanges.

Authority / court
U.S. Commodity Futures Trading Commission (CFTC)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Section 4(a) Commodity Exchange Act (7 U.S.C. § 6(a)); Beihilfe nach Section 13(a) (7 U.S.C. § 13c(a))
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
29 Jun 2026

Original amount 2,500,000 USD, converted at the ECB reference rate of 26 Jun 2026.

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

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25 Jun 2026 Kochava Inc. und Collective Data Solutions, LLCKochava: court order ends FTC lawsuit over trade in location data USAData subject rights and transparency Order

After almost four years of litigation, the federal district court for Idaho entered an order agreed between the FTC and the data broker Kochava. The FTC had alleged that Kochava sold precise location data from hundreds of millions of mobile devices without the knowledge and consent of the people concerned, revealing, for example, visits to health facilities and places of worship. Kochava and its subsidiary Collective Data Solutions, which has taken over the data broker business, may only share sensitive location data with affirmative consent and for services requested by the consumer, and must introduce, among other things, a sensitive-locations programme, checks on their data suppliers, disclosure of recipients and retention limits; no payment is provided for. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

Anyone who buys or passes on location data must verify consent at the source and consistently filter out sensitive locations.

Relevance to training and awareness

Location data as sensitive data; due diligence when buying and reselling data

Authority / court
U.S. District Court for the District of Idaho auf Klage der Federal Trade Commission (FTC)
Area of law
Data protection · Data subject rights and transparency
Legal basis
Section 5 FTC Act, 15 U.S.C. § 45 (unlautere Praktiken); Verfahren nach Section 13(b), 15 U.S.C. § 53(b)
Action
Order
Status of proceedings
final
Sector
Telecoms, IT and software
Published
26 Jun 2026

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

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24 Jun 2026 The Chemours Company; The Chemours Company FC, LLCChemours: USD 22.5m civil penalty in PFAS settlement with EPA and West Virginia USAEmissions and permits €19.8m

The EPA, the US Department of Justice and West Virginia's environmental agency reached a settlement (consent decree) with Chemours over PFAS discharges into the Cape Fear, Delaware and Ohio rivers, some made without and some in breach of discharge permits, together with TSCA and RCRA violations at four plants. Chemours will pay a civil penalty of 22,500,000 USD in three annual instalments of 7,500,000 USD and carry out remedial measures, including drinking water supply, PFAS controls and a USD 90m mitigation programme, which the EPA puts at over USD 450m in total. The settlement was lodged with the court on 24 June 2026 and is subject to public comment and court approval. The authority allegedly made the findings set out here; this account is not based on a final judgment. The decision is not final.

What organisations can take from it

PFAS manufacturers must continuously check every discharge against their permits – unregulated flows lead to penalties and costly obligations towards local residents.

Relevance to training and awareness

Discharge permits and PFAS emissions

Authority / court
U.S. Environmental Protection Agency (EPA) / U.S. Department of Justice mit West Virginia Department of Environmental Protection (U.S. District Court, Southern District of West Virginia)
Area of law
Environment and sustainability · Emissions and permits
Legal basis
Clean Water Act (NPDES); Resource Conservation and Recovery Act; Toxic Substances Control Act; West Virginia Water Pollution Control Act
Action
Fine
Status of proceedings
not yet final
Sector
Chemicals and pharmaceuticals
Mitigating circumstances
The civil penalty was set on the basis of the company's ability to pay.
Published
24 Jun 2026

Original amount 22,500,000 USD, converted at the ECB reference rate of 24 Jun 2026.

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

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23 Jun 2026 Denka Performance Elastomer, LLCDenka Performance Elastomer: USD 996,703 over hazardous waste at neoprene plant USAWaste and hazardous substances €874,915

The EPA (Region 6) issued a Consent Agreement and Final Order against Denka Performance Elastomer over RCRA violations at its neoprene plant in LaPlace (Louisiana): missing waste determinations, breaches of land disposal restrictions and treatment and storage of hazardous waste without a permit. Denka will pay 996,703.35 USD and must clean out a brine pit and its ancillary equipment; if the currently idle plant resumes operations, further requirements apply, including on waste inventory, containers, training and protective equipment. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

Every waste stream needs a documented determination of whether it is hazardous – without it there is no basis for lawful storage, treatment and disposal.

Relevance to training and awareness

Classification and storage of hazardous waste

Missing or inadequate training played a role in the decision.

Authority / court
U.S. Environmental Protection Agency (EPA), Region 6
Area of law
Environment and sustainability · Waste and hazardous substances
Legal basis
Resource Conservation and Recovery Act (RCRA), Docket RCRA-06-2025-0910
Action
Fine
Status of proceedings
final
Sector
Chemicals and pharmaceuticals
Repeat case
yes
Published
2 Jul 2026

Original amount 996,703.35 USD, converted at the ECB reference rate of 23 Jun 2026.

Checked against the official source on 3 Oct 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 USAForced and child labour 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.

What organisations can take from it

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

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 USAOther €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.

What organisations can take from it

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 USACommercial bribery €25.9m

The Arkansas pathology laboratory and its management company allegedly granted unlawful kickbacks and ordered medically unnecessary tests. The settlement of 30 million USD is a joint payment by all settling parties; the laboratory entered into a Corporate Integrity Agreement.

What organisations can take from it

Where services are sold through referrals, all benefits to referrers belong in a central approval and review procedure.

Relevance to training and awareness

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
Measures against individuals are not reported here.

Original amount 30,000,000 USD, converted at the ECB reference rate of 17 Jun 2026.

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

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16 Jun 2026 Robert Bosch GmbHBosch pays 36 million USD for sensor supplies to Huawei USAExport control and dual-use goods €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.

What organisations can take from it

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.

Relevance to training and awareness

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.

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 USAForced and child labour 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).

What organisations can take from it

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

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

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9 Jun 2026 Xponential Fitness, Inc. u. a. (Franchisegesellschaften der Marken AKT, BFT, Club Pilates, CycleBar, Pure Barre, Rumble, StretchLab, YogaSix)New York: Xponential Fitness pays 3.97 million USD over misleading franchise disclosures USA, NYConsumer protection and online retail €3.43m

According to the Attorney General's office, the fitness franchisor stated three to six months until studio opening in the disclosure documents filed in New York, although it took more than 13 months on average and its own SEC reports showed longer periods. The Assurance of Discontinuance requires 3,971,250 USD: 3 million USD for 70 harmed franchisees (of which 300,000 USD is a civil penalty) and 971,250 USD in fee refunds to 25 franchisees who never opened. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

Statements in franchise disclosures must match the company's own capital market reports – discrepancies count as evidence of deception.

Relevance to training and awareness

Realistic statements in franchise disclosure documents

Authority / court
Office of the New York State Attorney General (Investor Protection Bureau, Franchise Section)
Area of law
Consumer protection and online retail
Legal basis
New York Franchise Sales Act (General Business Law §§ 680 ff., insb. § 687); Executive Law § 63(12)
Action
Disgorgement of profits
Status of proceedings
final
Sector
Other
Published
9 Jun 2026

Original amount 3,971,250 USD, converted at the ECB reference rate of 9 Jun 2026.

Checked against the official source on 3 Oct 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 USAData breaches and data security 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.

What organisations can take from it

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

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 USAMerger control 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.

What organisations can take from it

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

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

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1 Jun 2026 FTI Consulting, Inc.OFAC: USD 1.05 million settlement with FTI Consulting over prohibited extension of credit to a Russian state-owned bank USABreaches of sanctions and embargoes €901,597

Consulting firm FTI Consulting, Inc. of Washington, D.C. is paying USD 1,050,000 under a settlement with OFAC for apparent violations of the Russia financial sector sanctions. According to OFAC's findings, between April 2019 and May 2021 FTI indirectly extended prohibited debt on six occasions to a Russian state-owned bank subject to Directive 1 under Executive Order 13662: invoices remained unpaid beyond the permitted 14 days or were paid long afterwards while FTI continued to provide services. OFAC treated the apparent violations as non-egregious and not voluntarily self-disclosed; the base penalty was USD 525,000. The settlement amount is above the base penalty; OFAC cited in particular the anticipated impact on future compliance by similarly situated firms. Source: U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC), enforcement release "FTI Consulting, Inc., a Global Business Advisory Firm, Settles with OFAC for $1,050,000 Related to Apparent Violations of Dealing in Prohibited Debt of Sanctioned Russian Bank", 1 June 2026, https://ofac.treasury.gov/media/935651/download?inline; summarised in our own words.

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. §§ 589.202, 589.213 i. V. m. Directive 1 zu E.O. 13662 (sechs mutmaßliche Verstöße); Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A
Action
Fine
Status of proceedings
final
Sector
Other
Published
1 Jun 2026

Original amount 1,050,000 USD, converted at the ECB reference rate of 1 Jun 2026.

Checked against the official source on 28 Sep 2026 · Version 3 · 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 USARetaliation against whistleblowers €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.

What organisations can take from it

When cleaning up clauses, all contract templates must be covered – a single forgotten template is enough for a violation.

Relevance to training and awareness

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.

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

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20 May 2026 Farjess Inc. und Royal Canadian Steel Inc.Canadian steel companies pay 19 million USD – steel from Asia and Europe declared as Canadian USACustoms €16.4m

Two Canadian steel companies allegedly declared flat-rolled steel from China, Indonesia, Italy, Turkey and Vietnam to US customs as being of Canadian or US origin from May 2019 to January 2025. The settlement of 19 million USD (a joint payment with a further settling party) resolves the lawsuit of a customs broker, who receives around 3.61 million USD.

What organisations can take from it

Base origin declarations in cross-border trade on mill certificates – and take note that your own customs broker is often the first to spot inconsistencies.

Relevance to training and awareness

Proof of origin in steel trading

Authority / court
U.S. Department of Justice, Civil Division, und U.S. Attorney’s Office Eastern District of Michigan
Area of law
Sanctions and export control · Customs
Legal basis
False Claims Act, 31 U.S.C. §§ 3729 ff. (Vergleich; Haftung nicht festgestellt)
Action
Other
Status of proceedings
final
Sector
Steel and metals
Liability of senior managers
Measures against individuals are not reported here.
Published
20 May 2026

Original amount 19,000,000 USD, converted at the ECB reference rate of 20 May 2026.

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

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18 May 2026 Adani Enterprises LimitedAdani Enterprises pays 275 million USD over Iranian liquefied petroleum gas USABreaches of sanctions and embargoes €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).

What organisations can take from it

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.

Relevance to training and awareness

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.

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 USA, CAEmissions and permits €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.

What organisations can take from it

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 USAGifts, hospitality and benefits €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.

What organisations can take from it

Speaker programmes need a demonstrable educational purpose – repeated attendance and expensive hospitality turn them into inducements.

Relevance to training and awareness

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.

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

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12 May 2026 Perfectus Aluminum Inc., Perfectus Aluminum Acquisitions LLC und vier verbundene LagergesellschaftenPerfectus Aluminum: 549.5 million USD – aluminium extrusions imported as sham pallets USACustoms €468.1m

From July 2011 to June 2014, the companies imported more than 2.2 million Chinese aluminium extrusions that had merely been spot-welded into “pallets”, and declared them as finished goods not subject to anti-dumping and countervailing duties – there were never any buyers for the pallets. A jury had already convicted the companies in 2021 of, among other things, conspiracy to defraud the United States; the civil settlement of 549.5 million USD resolves several whistleblower lawsuits.

What organisations can take from it

Do not use minimal processing to declare goods as finished products outside the scope of anti-dumping duties – that is duty evasion; classify goods according to what they actually are.

Relevance to training and awareness

Tariff classification and evasion of anti-dumping duties

Authority / court
U.S. Department of Justice, Civil Division, und U.S. Attorney’s Office Central District of California
Area of law
Sanctions and export control · Customs
Legal basis
False Claims Act, 31 U.S.C. §§ 3729 ff. (zivilrechtlicher Vergleich)
Action
Other
Status of proceedings
final
Sector
Steel and metals
Culpability
intentional
Published
12 May 2026

Original amount 549,500,000 USD, converted at the ECB reference rate of 12 May 2026.

Checked against the official source on 28 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 USACommercial bribery €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.

What organisations can take from it

Remuneration of business partners who refer work must correspond to the market value of the service – any overpayment acts as a bribe.

Relevance to training and awareness

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.

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 USA, NYSecurity measures and risk management €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.

What organisations can take from it

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.

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 USAGifts, hospitality and benefits €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.

What organisations can take from it

Fee programmes for customers who drive revenue can become part of a criminal overall scheme – with consequences that threaten the company’s existence.

Relevance to training and awareness

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.

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

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17 Apr 2026 General Electric CompanyDDTC: USD 36 million against General Electric for technical data exports to China USAExport control and dual-use goods €30.5m

The DDTC settled with General Electric Company for a civil penalty of USD 36 million for ITAR violations: unauthorised exports of technical data to the People's Republic of China, breaches of authorisation provisos, unauthorised exports of defence articles and failure to report material changes to its ITAR registration. USD 18 million is suspended for approved compliance measures and USD 18 million is payable in three instalments. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

Changes to one's own ITAR registration must also be reported and belong in the compliance calendar.

Relevance to training and awareness

ITAR registration and control of technical data with a China link

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
Employees
10,000 or more
Mitigating circumstances
The allegations are based on facts that the company itself disclosed to the DDTC.

Original amount 36,000,000 USD, converted at the ECB reference rate of 17 Apr 2026.

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

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13 Apr 2026 Coastal PVA Technology, Inc.Coastal PVA: 1.7 million USD (suspended) for brushes sold to SMIC – without an export compliance programme USAExport control and dual-use goods €1.45m

The Californian manufacturer of PVA brushes for wafer cleaning sold goods worth around 400,000 USD on 18 occasions between 2021 and 2024 via two Chinese distributors to SMIC Beijing and SMIC North, both on the Entity List (the US export control list of restricted parties). The company had no formal export compliance rules; the penalty of 1.7 million USD is suspended for one year owing to limited ability to pay and will be waived if training and an internal audit are completed on time.

What organisations can take from it

Obtain a licence even for unlisted everyday goods (EAR99) when the end customer is on the Entity List – without end-customer screening, routing sales through distributors does not help.

Relevance to training and awareness

Export controls for EAR99 goods and deliveries via distributors

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, 15 C.F.R. § 764.2(a), § 744.11
Action
Fine
Status of proceedings
final
Sector
Manufacturing and mechanical engineering
Culpability
negligent
Mitigating circumstances
Payment suspended owing to demonstrated limited ability to pay; deliveries stopped after notification by BIS (Bureau of Industry and Security).
Published
14 Apr 2026

Original amount 1,700,000 USD, converted at the ECB reference rate of 13 Apr 2026.

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

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10 Apr 2026 StubHub Holdings, Inc.FTC: StubHub refunds 10 million USD over ticket prices shown without mandatory fees USAMisleading advertising and pricing Disgorgement of profits

According to the FTC, StubHub displayed ticket prices on its website without clearly and conspicuously stating up front the total price including all mandatory fees. The court order relies on the new FTC rule against unfair or deceptive fees and requires StubHub to pay 10 million USD for consumer refunds. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

Since the FTC fees rule, the first price shown for tickets must include all mandatory fees.

Relevance to training and awareness

Total price display including mandatory fees (drip pricing)

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
9 Apr 2026

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

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30 Mar 2026 Peken Global Limited (KuCoin)Peken Global (KuCoin): 500,000 USD and ban on US access without CFTC registration USAOrganisational requirements €435,388

On a complaint by the CFTC, the federal court in New York entered a consent order against the operator of the KuCoin crypto exchange, which is registered in the Turks and Caicos Islands. Peken Global had given US participants direct access to its trading system without being registered with the CFTC as a foreign board of trade; the court permanently prohibited this and imposed a fine of 500,000 USD. Disgorgement was waived because of the cooperation and the forfeiture in the parallel criminal case, in which Peken Global had pleaded guilty to operating an unlicensed money transmitting business. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

Anyone giving US participants direct access to a foreign trading platform needs the appropriate CFTC registration or must effectively block such access.

Authority / court
U.S. District Court for the Southern District of New York (auf Klage der CFTC)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
CFTC Regulation 48.3 (17 C.F.R. § 48.3); Section 6c Commodity Exchange Act (7 U.S.C. § 13a-1)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Cooperation with the CFTC and in the criminal proceedings; because of the forfeiture ordered there, the CFTC did not seek disgorgement.
Published
30 Mar 2026

Original amount 500,000 USD, converted at the ECB reference rate of 30 Mar 2026.

Checked against the official source on 3 Oct 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 USAOther €9.11m

The metal fabrication companies 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 joint payment with a further settling party); a former employee received 1,863,750 USD as a whistleblower.

What organisations can take from it

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
Measures against individuals are not reported here.
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 28 Sep 2026 · Version 3 · 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 USABribery of public officials €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.

What organisations can take from it

Physicians at public hospitals are public officials – consultancy agreements with them require documented services and approval by the compliance function.

Relevance to training and awareness

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
Measures against individuals are not reported here.
Published
19 Mar 2026

Original amount 1,214,797 USD, converted at the ECB reference rate of 17 Mar 2026.

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

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17 Mar 2026 TradeStation Securities, Inc.OFAC: USD 1.11 million settlement with TradeStation over securities trading for customers in Iran, Syria and Crimea USABreaches of sanctions and embargoes €963,196

Online broker TradeStation Securities, Inc. of Florida is paying USD 1,110,661 under a settlement with OFAC for 481 apparent violations of multiple sanctions programmes. According to OFAC's findings, following several failures in compliance controls, customers in Iran, Syria and Crimea were able to execute 481 securities trades worth a total of USD 4,442,645 via the mobile app between June 2021 and June 2022. OFAC treated the apparent violations as non-egregious and voluntarily self-disclosed and credited significant remedial measures; the base penalty was USD 2,221,322. Source: U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC), enforcement release "TradeStation Securities, Inc. Settles with OFAC for $1,110,661 Related to Apparent Violations of Multiple Sanctions Regulations", 17 March 2026, https://ofac.treasury.gov/media/935351/download?inline; summarised in our own words.

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. § 560.204; Syrian Sanctions Regulations, 31 C.F.R. § 542.207; Ukraine-/Russia-Related Sanctions Regulations, 31 C.F.R. § 589.207 (481 mutmaßliche Verstöße); Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
17 Mar 2026

Original amount 1,110,661 USD, converted at the ECB reference rate of 17 Mar 2026.

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

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6 Mar 2026 Canaccord Genuity LLCFinCEN: 80 million USD against Canaccord Genuity over AML and correspondent banking deficiencies USACustomer due diligence €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.

What organisations can take from it

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 USACommercial bribery €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.

What organisations can take from it

Early self-disclosure limits the damage – but this requires the compliance function to actually get to see problematic sales contracts.

Relevance to training and awareness

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.

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

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3 Mar 2026 Walmart Inc.FTC and eleven states: 100 million USD against Walmart over Spark driver pay USAMisleading advertising and pricing €86.2m

According to the FTC and eleven states, Walmart misled the drivers of its Spark Driver delivery service about base pay, incentives and tips, so that they lost tens of millions of dollars in earnings. The court order comprises judgments of 100 million USD: 89 million USD for the FTC (of which 10 million USD is paid and 16,175,302 USD goes into a driver fund, the remainder suspended because of back payments already made) and 11 million USD for the states. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

Earnings claims made to drivers and freelancers are advertising claims and must match what is actually paid out.

Relevance to training and awareness

Truthful earnings claims towards gig workers

Authority / court
Federal Trade Commission (FTC) mit elf Bundesstaaten (AZ, CA, CO, IL, MI, NC, OK, PA, SC, UT, WI)
Area of law
Consumer protection and online retail · Misleading advertising and pricing
Legal basis
Section 5 FTC Act; Gramm-Leach-Bliley Act (15 U.S.C. §§ 6801–6809, 6821–6827); Verbraucherschutzgesetze der klagenden Bundesstaaten
Action
Disgorgement of profits
Status of proceedings
final
Sector
Retail and e-commerce
Employees
10,000 or more
Published
26 Feb 2026

Original amount 100,000,000 USD, converted at the ECB reference rate of 3 Mar 2026.

Checked against the official source on 3 Oct 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 USAExport control and dual-use goods €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.

What organisations can take from it

Actively incorporate new forms of listing, such as address-only entries, into screening; do not rely solely on the software provider.

Relevance to training and awareness

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.

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 USA, CAWorkplace safety and accidents €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.

What organisations can take from it

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.

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

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24 Feb 2026 Vizocom ICTVizocom: blueprints for military antenna sent to China and copies supplied to the US Navy USAExport control and dual-use goods €317,971

The Californian dealer had won a Navy contract for 450 VHF/UHF antennas from a US manufacturer, but in 2019 uploaded the export-controlled production specifications of the purely military antenna without a licence to the portal of a Chinese manufacturer, had the antennas produced there for 6 USD each and supplied them to the Navy with false manufacturer information for 165,109.50 USD. The Bureau of Industry and Security (BIS, the export control agency of the US Department of Commerce) imposed 374,474 USD in 20 instalments and a denial of export privileges suspended for five years.

What organisations can take from it

Do not send specifications of military goods to foreign manufacturers without a licence – even uploading a drawing to a supplier portal is an export.

Relevance to training and awareness

Technical drawings and specifications as export-controlled technology

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), §§ 742.4, 742.6 (ECCN 3E611)
Action
Fine
Status of proceedings
final
Sector
Defence and security
Culpability
intentional
Liability of senior managers
Measures against individuals are not reported here.
Published
25 Feb 2026

Original amount 374,474 USD, converted at the ECB reference rate of 24 Feb 2026.

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

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12 Feb 2026 IMG Academy, LLCOFAC: USD 1.72 million settlement with IMG Academy over school contracts with two sanctioned individuals USABreaches of sanctions and embargoes €1.45m

School and sports academy IMG Academy, LLC of Bradenton, Florida, is paying USD 1,720,000 under a settlement with OFAC for apparent violations of the counternarcotics sanctions. According to OFAC's findings, between 2019 and 2025 IMG Academy entered into tuition agreements for the children of two individuals on the SDN List because of their ties to a sanctioned Mexican drug cartel and processed the related payments; 89 dealings were involved in total. OFAC treated the apparent violations as non-egregious and not voluntarily self-disclosed because an investigation was already under way when the academy reported them; the settlement amount equals the base penalty. Source: U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC), enforcement release "IMG Academy, LLC Settles with OFAC for $1.7 Million Related to Apparent Violations of Counternarcotics Sanctions", 12 February 2026, https://ofac.treasury.gov/media/935006/download?inline; summarised in our own words.

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
Foreign Narcotics Kingpin Sanctions Regulations, 31 C.F.R. § 598.202 (89 mutmaßliche Verstöße); Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A
Action
Fine
Status of proceedings
final
Sector
Other
Published
12 Feb 2026

Original amount 1,720,000 USD, converted at the ECB reference rate of 12 Feb 2026.

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

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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 USAExport control and dual-use goods €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.

What organisations can take from it

Routing through foreign subsidiaries does not remove the licence requirement; export control needs audits and clear accountability of management.

Relevance to training and awareness

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.

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 USA, CACookies and tracking €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.

What organisations can take from it

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 USAInternal controls €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.

What organisations can take from it

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.

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 USA, CAMinimum wage and undeclared work €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.

What organisations can take from it

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 USAForced and child 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).

What organisations can take from it

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
Sources

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 USADisclosure and reporting obligations €33.5m

ADM 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 to 20 %. ADM is paying a civil penalty of 40 million USD.

What organisations can take from it

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
Measures against individuals are not reported here.

Original amount 40,000,000 USD, converted at the ECB reference rate of 27 Jan 2026.

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

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26 Jan 2026 DME Construction Associates Inc.DME Construction Associates: USD 600,000 OSHA settlement after fatal roof fall USAWorkplace safety and accidents €506,928

Long Island roofing contractor DME Construction Associates entered into a settlement with the US Department of Labor affirming all citations issued after an employee fell to his death through an unprotected skylight in August 2021, including nine wilful violations, eight of them cited per instance for each unprotected employee. The company will pay 600,000 USD and must introduce a written safety plan, ensure sufficient fall protection for all workers, notify OSHA of jobs in advance, allow inspections without a warrant and have supervisors complete a 30-hour course. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

Missing fall protection can be penalised separately for each employee.

Relevance to training and awareness

Fall protection on roofs

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
Occupational Safety and Health Act (Absturzsicherung im Bauwesen)
Action
Fine
Status of proceedings
final
Sector
Construction and real estate
Culpability
intentional
Liability of senior managers
Measures against individuals are not set out here.
Published
26 Jan 2026

Original amount 600,000 USD, converted at the ECB reference rate of 26 Jan 2026.

Checked against the official source on 3 Oct 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 USAMisleading advertising and pricing €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.

What organisations can take from it

Anyone advertising something as "free" must not add a mandatory fee elsewhere.

Relevance to training and awareness

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
Employees
1,000 to 9,999
Published
18 Dec 2025

Original amount 60,000,000 USD, converted at the ECB reference rate of 13 Jan 2026.

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

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13 Jan 2026 General Motors LLC, General Motors Holdings LLC und OnStar, LLCGeneral Motors/OnStar: FTC order after sale of location and driving data USAMarketing and consent Order

The FTC finalised its order against General Motors and OnStar. According to the authority, GM used a misleading enrolment process to sign customers up for the OnStar service and the Smart Driver feature, collected precise location and driving behaviour data from millions of vehicles and sold it to third parties, including consumer reporting agencies, without clear notice and affirmative consent. GM may not disclose this data to consumer reporting agencies for five years and, for the 20-year term of the order, must obtain affirmative consent before collecting, using or sharing connected vehicle data, allow access and deletion, and offer a way to disable location collection; the order does not provide for any payment. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

Data from connected products may only be passed to third parties after clear notice and affirmative consent – a tick box in the enrolment process is no substitute.

Relevance to training and awareness

Consent for connected products; sharing of location and usage data

Authority / court
Federal Trade Commission (FTC)
Area of law
Data protection · Marketing and consent
Legal basis
Section 5(a) FTC Act, 15 U.S.C. § 45(a) (unlautere und irreführende Praktiken)
Action
Order
Status of proceedings
final
Sector
Automotive
Employees
10,000 or more
Published
14 Jan 2026

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

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7 Jan 2026 Exyte Management GmbHExyte: 1.5 million USD – Chinese subsidiary arranged US goods for listed chipmaker SMIC USAExport control and dual-use goods €1.28m

The Shanghai company of the Stuttgart-based Exyte group caused around 884 US items (flowmeters, pressure transmitters, controllers) worth around 2.85 million USD to be delivered by Chinese suppliers to SMIC Beijing, which is on the Entity List (the US export control list of restricted parties), on 13 occasions in 2021/22. According to the Bureau of Industry and Security (BIS, the export control agency of the US Department of Commerce), the compliance programme did not recognise that in-country transfers within China also require a licence; Exyte voluntarily disclosed the transactions and admitted them.

What organisations can take from it

Screen end customers against the Entity List in foreign subsidiaries too, even for local purchases – US export law also covers transfers of US goods within China.

Relevance to training and awareness

Entity List screening also for domestic deliveries abroad

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(b), § 744.11
Action
Fine
Status of proceedings
final
Sector
Construction and real estate
Culpability
negligent
Mitigating circumstances
Voluntary self-disclosure, own investigation with external lawyers and investment in the compliance programme.
Published
7 Jan 2026

Original amount 1,500,000 USD, converted at the ECB reference rate of 7 Jan 2026.

Checked against the official source on 28 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 USA, CAMarketing and consent €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.

What organisations can take from it

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.

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

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23 Dec 2025 Disney Worldwide Services, Inc. und Disney Entertainment Operations LLCDisney: 10 million USD over mislabelled children's videos on YouTube USAMarketing and consent €8.48m

On a complaint filed by the U.S. Department of Justice on behalf of the FTC, the federal district court for the Central District of California entered an order against two Disney companies. Disney is alleged to have failed to label child-directed videos on YouTube as 'Made for Kids' because it designated audiences only at channel level; as a result, data from children under 13 could be collected via YouTube without notice to and consent from their parents and used for targeted advertising. Disney pays a civil penalty of 10,000,000 USD and must set up a programme for reviewing and designating the audience of its videos. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

A company distributing content through third-party platforms remains responsible for their privacy settings – channel-level defaults must be checked for each piece of content.

Relevance to training and awareness

Children's privacy for content on third-party platforms; maintaining platform settings

Authority / court
Federal Trade Commission (FTC); Klage durch das U.S. Department of Justice, Anordnung des U.S. District Court for the Central District of California
Area of law
Data protection · Marketing and consent
Legal basis
COPPA Rule, 16 C.F.R. Part 312; Children's Online Privacy Protection Act, 15 U.S.C. §§ 6502(c), 6505(d); Verfahren nach 15 U.S.C. §§ 45(m)(1)(A), 53(b)
Action
Fine
Status of proceedings
final
Sector
Media and online platforms
Employees
10,000 or more
Published
31 Dec 2025

Original amount 10,000,000 USD, converted at the ECB reference rate of 23 Dec 2025.

Checked against the official source on 3 Oct 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 USACommercial bribery €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.

What organisations can take from it

Cooperation agreements between hospitals and office-based practices must properly document services and remuneration – otherwise payments are treated as referral bonuses.

Relevance to training and awareness

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.

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

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18 Dec 2025 Ceratizit USA LLCCeratizit USA: 54.4 million USD for misdeclared carbide products from China USACustoms €46.4m

The distributor of tungsten carbide products allegedly transshipped Chinese goods via Taiwan and declared them as Taiwanese (2020–2024), misclassified products (2015–2024) and distributed goods without country-of-origin marking. The settlement of 54.4 million USD resolves a whistleblower lawsuit; the whistleblower receives around 9.75 million USD.

What organisations can take from it

Treat origin, tariff classification and marking as three separate obligations – customs compliance that checks only one of them leaves the other risks open.

Relevance to training and awareness

Tariff classification, origin declarations and origin marking

Authority / court
U.S. Department of Justice, Civil Division, und U.S. Attorney’s Office Eastern District of Michigan
Area of law
Sanctions and export control · Customs
Legal basis
False Claims Act, 31 U.S.C. §§ 3729 ff. (Vergleich; Haftung nicht festgestellt)
Action
Other
Status of proceedings
final
Sector
Steel and metals
Published
18 Dec 2025

Original amount 54,400,000 USD, converted at the ECB reference rate of 18 Dec 2025.

Checked against the official source on 28 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 USAForced and child labour 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)).

What organisations can take from it

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

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

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9 Dec 2025 Paxful, Inc. und Paxful USA, Inc.FinCEN: USD 3.5 million against crypto platform Paxful for failing to register and AML failures USAInternal controls €3.01m

FinCEN imposed a civil money penalty of USD 3.5 million on the peer-to-peer virtual currency trading platform Paxful, Inc. and Paxful USA, Inc. From February 2015 to April 2023 Paxful did not maintain an effective AML programme for its trading platform and hosted wallets and did not report suspicious transactions accurately and on time; the company also allowed its registration as a money services business to lapse and operated unregistered from January 2017 to September 2019 (974 days). Payments of USD 1.75 million to the DOJ are credited against the penalty; USD 1.75 million is payable to FinCEN. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

Crypto marketplaces must ensure registration, including timely renewal, customer due diligence and suspicious activity reporting from the outset and keep them in step with growth.

Relevance to training and awareness

AML duties of crypto platforms: registration, KYC and suspicious activity reporting

Authority / court
Financial Crimes Enforcement Network (FinCEN), U.S. Department of the Treasury
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
31 U.S.C. § 5330, § 5318(h)(1), § 5318(g)(1); 31 C.F.R. §§ 1022.380, 1022.210, 1022.320
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
FinCEN took into account that Paxful was forthcoming during the investigation, answered information requests completely and on time and agreed to toll the statute of limitations.

Original amount 3,500,000 USD, converted at the ECB reference rate of 9 Dec 2025.

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

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4 Dec 2025 Gracetown, Inc.OFAC: USD 7.14 million penalty on Gracetown over payments for a blocked company and failure to file a blocking report USABreaches of sanctions and embargoes €6.12m

OFAC has imposed a penalty of USD 7,139,305 on New York property management company Gracetown, Inc. by way of a Penalty Notice. According to OFAC's findings, between April 2018 and May 2020 Gracetown received 24 payments on behalf of an affiliated company owned by a sanctioned Russian oligarch, although OFAC had previously given it explicit notice of the prohibition. Gracetown also failed to report the blocked property to OFAC for more than 45 months. OFAC regarded the violations as wilful or at least reckless, egregious and not voluntarily self-disclosed; the base penalty equalled the statutory maximum of USD 8,906,358. OFAC's publication does not state whether Gracetown has paid the penalty or challenged it in court. Source: U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC), enforcement release "OFAC Imposes $7,139,305 Penalty on Gracetown, Inc. for Violating Ukraine-/Russia-Related Sanctions and Reporting Obligations", 4 December 2025, https://ofac.treasury.gov/media/934796/download?inline; summarised in our own words.

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. § 589.201; Reporting, Procedures and Penalties Regulations, 31 C.F.R. § 501.603 (Sperrmeldung); Penalty Notice nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A
Action
Fine
Status of proceedings
unknown
Sector
Construction and real estate
Published
4 Dec 2025

Original amount 7,139,305 USD, converted at the ECB reference rate of 4 Dec 2025.

Checked against the official source on 28 Sep 2026 · Version 3 · 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 USAFake reviews €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 is paying 150,000 USD jointly with other liable parties (joint payment), which is earmarked for refunds.

What organisations can take from it

"Buying off" negative reviews with vouchers is just as misleading as inventing positive ones.

Relevance to training and awareness

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
Measures against individuals are not reported here.
Published
3 Dec 2025

Original amount 150,000 USD, converted at the ECB reference rate of 3 Dec 2025.

Checked against the official source on 28 Sep 2026 · Version 3 · 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 USAMerger control 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.

What organisations can take from it

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

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 USABreaches of sanctions and embargoes €9.89m

In 2017/2018, the Chicago fund manager specialising in data centres took in capital from a Russian oligarch 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.

What organisations can take from it

Screen investors through to the beneficial owner and re-check them when new designations occur – nested structures do not protect against liability.

Relevance to training and awareness

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.

Checked against the official source on 27 Sep 2026 · Version 2 · Direct link

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26 Nov 2025 Harman International Industries, Inc.Harman pays 11.8 million USD – anti-dumping duty on aluminium heat sinks not paid USACustoms €10.2m

The audio electronics group (brands include Harman Kardon and JBL) allegedly imported heat sinks made of Chinese extruded aluminium from 2011 to 2023 without paying the anti-dumping and countervailing duties owed; after the failure was brought to its attention, the company allegedly did not disclose it. The settlement of 11,809,628 USD resolves a whistleblower lawsuit (share around 2.3 million USD).

What organisations can take from it

Disclose customs errors voluntarily once identified – concealment turns an oversight into deliberate deception; build corrective filings into the process.

Relevance to training and awareness

Anti-dumping duties on components and disclosure of identified errors

Authority / court
U.S. Attorney’s Office Eastern District of Michigan (Department of Justice) mit CBP und Department of Commerce
Area of law
Sanctions and export control · Customs
Legal basis
False Claims Act, 31 U.S.C. §§ 3729 ff. (Vergleich; Haftung nicht festgestellt)
Action
Other
Status of proceedings
final
Sector
Manufacturing and mechanical engineering
Published
26 Nov 2025

Original amount 11,809,628 USD, converted at the ECB reference rate of 26 Nov 2025.

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

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25 Nov 2025 Lowe's Home Centers, LLCLowe's Home Centers: USD 12.5m over breaches of lead paint rules USAWaste and hazardous substances €10.8m

In a second consent decree, Lowe's Home Centers undertakes to pay a civil penalty of allegedly 12,500,000 USD and to introduce a company-wide programme so that the installation firms it hires work lead-safely in homes built before 1978. The EPA had found breaches of the Lead Renovation, Repair and Painting Rule on more than 250 renovation jobs in 23 states, mostly from 2019 to 2021, such as missing certified renovators, missing customer information and inadequate dust containment, as well as breaches of a 2014 settlement. The settlement was lodged with the court on 25 November 2025. The authority allegedly made the findings set out here; this account is not based on a final judgment. The decision is not final.

What organisations can take from it

Companies that outsource trade work to subcontractors remain responsible for their certification and work practices and must be able to show how they manage this.

Relevance to training and awareness

Managing subcontractors on renovations involving lead paint

Missing or inadequate training played a role in the decision.

Authority / court
U.S. Environmental Protection Agency (EPA) / U.S. Department of Justice (U.S. District Court, Central District of California)
Area of law
Environment and sustainability · Waste and hazardous substances
Legal basis
Toxic Substances Control Act (TSCA), Lead Renovation, Repair and Painting Rule; Consent Decree von 2014
Action
Fine
Status of proceedings
unknown
Sector
Retail and e-commerce
Employees
10,000 or more
Repeat case
yes
Published
25 Nov 2025

Original amount 12,500,000 USD, converted at the ECB reference rate of 25 Nov 2025.

Checked against the official source on 4 Oct 2026 · Direct link

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24 Nov 2025 Taylor Farms New Jersey Inc.Taylor Farms New Jersey: USD 1.13m in OSHA penalties after fatal cleaning accident USAWorkplace safety and accidents €974,951

After an employee was fatally injured while cleaning a machine at the fresh-cut vegetable plant in Swedesboro (New Jersey) in May 2025, OSHA cited Taylor Farms New Jersey, a subsidiary of Taylor Fresh Foods, for 16 violations, which it describes as wilful and repeated, and proposed penalties of 1,125,484 USD; the allegations concern missing lockout/tagout procedures and lack of training. The on-site staffing agency PL Solutions Group LLC (People Logistics) received three separate citations with 33,100 USD. The companies could contest the citations before the Occupational Safety and Health Review Commission. The authority allegedly made the findings set out here; this account is not based on a final judgment. The decision is not final.

What organisations can take from it

Cleaning production equipment is maintenance – without energy isolation and lockout there is a risk to life, including for agency workers.

Relevance to training and awareness

Isolating energy during cleaning and maintenance

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
Occupational Safety and Health Act; OSHA-Standard zur Kontrolle gefährlicher Energien (Lockout/Tagout)
Action
Fine
Status of proceedings
not yet final
Sector
Food and agriculture
Repeat case
yes
Published
24 Nov 2025

Original amount 1,125,484 USD, converted at the ECB reference rate of 24 Nov 2025.

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

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21 Nov 2025 Jam City, Inc.Jam City: 1.4 million USD in California over missing opt-outs in 21 gaming apps USA, CAData subject rights and transparency €1.22m

On a complaint by the California Attorney General, the Superior Court in Los Angeles entered a stipulated judgment against the mobile game developer Jam City. According to the investigation, none of Jam City's 21 apps offered a way, as required by the California Consumer Privacy Act (CCPA), to opt out of the sale or sharing of personal data for personalised advertising, and some games passed on data of teenagers aged between 13 and 16 without their affirmative consent. Jam City pays 1,400,000 USD, must offer opt-out options within the apps, may only sell or share data of under-16s on an opt-in basis and must instruct recipients to delete such data. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

A business that shares data for advertising through apps must enable the opt-out where the data is collected – directly in the app.

Relevance to training and awareness

Right to opt out of data sales in apps; protecting minors in advertising tracking

Authority / court
Superior Court of California, County of Los Angeles, auf Klage des Attorney General of California (California Department of Justice)
Area of law
Data protection · Data subject rights and transparency
Legal basis
California Consumer Privacy Act (CCPA), Cal. Civ. Code § 1798.100 ff.; Zahlung nach Cal. Civ. Code § 1798.199.90
Action
Fine
Status of proceedings
final
Sector
Media and online platforms
Published
21 Nov 2025

Original amount 1,400,000 USD, converted at the ECB reference rate of 21 Nov 2025.

Checked against the official source on 3 Oct 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 USA, NVCustomer due diligence €6.77m

On 13 November 2025, the Nevada Gaming Control Board (NGCB) filed a disciplinary complaint for unsuitable methods of operation in connection with an illegal bookmaker 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).

What organisations can take from it

Casino staff must recognise high-risk players and unexplained sources of funds – revenue interests must not override AML obligations.

Relevance to training and awareness

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.

Checked against the official source on 27 Sep 2026 · Version 2 · Direct link

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19 Nov 2025 Exodus Movement, Inc.OFAC: USD 3.1 million settlement with Exodus over customer support for users in Iran USABreaches of sanctions and embargoes €2.68m

US fintech Exodus Movement, Inc. is paying USD 3,103,360 under a settlement with OFAC for 254 apparent violations of the Iran sanctions. According to OFAC's findings, Exodus provided customer support to users in Iran and in some cases helped them access third-party crypto exchanges through its own wallet software. According to OFAC, on twelve occasions staff, despite being aware of the sanctions, advised users to hide their location via VPN in order to circumvent those exchanges' controls; OFAC treated these instances as egregious. The apparent violations were not voluntarily disclosed; the base penalty was USD 4,774,400. Extensive remediation and cooperation were taken into account. Exodus satisfies USD 630,000 of the settlement amount by investing in additional sanctions controls; USD 2,473,360 is payable to the Treasury. OFAC signed the settlement agreement on 19 November 2025 and published it on 16 December 2025. According to the settlement agreement, the settlement does not constitute an admission by Exodus of the apparent violations. Source: U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC), enforcement release "Exodus Movement, Inc. Settles with OFAC for $3,103,360 for Apparent Violations of Iran-related Sanctions Regulations", 16 December 2025, https://ofac.treasury.gov/media/934831/download?inline; summarised in our own words.

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. § 560.204 (254 mutmaßliche Verstöße), in 12 Fällen zusätzlich § 560.203 (Umgehung); Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
16 Dec 2025

Original amount 3,103,360 USD, converted at the ECB reference rate of 19 Nov 2025.

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

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18 Nov 2025 Firemount Group Ltd.CBP stops clothing from Firemount Group in Mauritius USAForced and child labour 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).

What organisations can take from it

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

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 USAMerger control 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.

What organisations can take from it

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

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 USABribery of public officials €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.

What organisations can take from it

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.

Relevance to training and awareness

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).
Published
12 Dec 2025

Original amount 118,198,343 USD, converted at the ECB reference rate of 12 Nov 2025.

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

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31 Oct 2025 Google LLCTexas: Google pays $1.375 billion over location, incognito and biometric data USA, TXCookies and tracking €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.

What organisations can take from it

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.

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

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31 Oct 2025 JBS USA Food Company und JBS USA Food Company HoldingsNew York: JBS USA pays 1.1 million USD over unsubstantiated "Net Zero 2040" claims USA, NYMisleading environmental and sustainability claims Other

The Attorney General's office accused the US arm of the meat group JBS of publicly advertising a "net zero by 2040" goal without a viable plan to achieve it. After a first lawsuit had been dismissed without prejudice in January 2025, the parties concluded an Assurance of Discontinuance: JBS USA pays 1.1 million USD to a climate-smart agriculture programme (expressly not a fine), changes its environmental marketing and reports annually for three years. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

Net-zero promises are advertising claims and need a verifiable implementation plan, otherwise they are treated as misleading.

Relevance to training and awareness

Communicating climate targets only with a robust implementation plan

Authority / court
Office of the New York State Attorney General
Area of law
Environment and sustainability · Misleading environmental and sustainability claims
Legal basis
New York General Business Law §§ 349, 350; Executive Law § 63(12), § 63(15)
Action
Other
Status of proceedings
final
Sector
Food and agriculture
Published
3 Nov 2025

Checked against the official source on 3 Oct 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 USA, PAInformation duties in online retail €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.

What organisations can take from it

A purchase must not silently trigger a membership with monthly charges.

Relevance to training and awareness

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.

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 USA, CAWorking time €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 concealed the employer; the Notice of Final Findings of 21 October 2025 established 438,204 USD, with OptumCare jointly liable as the client.

What organisations can take from it

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
Measures against individuals are not reported here.
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 28 Sep 2026 · Version 2 · Direct link

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14 Oct 2025 Farmers Insurance ExchangeNYDFS: $2.775 million against Farmers over unprotected online quoting tools USA, NYSecurity measures and risk management €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.

What organisations can take from it

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.

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 USA, NYIncident reporting obligations €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.

What organisations can take from it

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.

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 USA, CAData subject rights and transparency €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).

What organisations can take from it

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.

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 USAInformation duties in online retail €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.

What organisations can take from it

Subscription sign-ups require an equally prominent option to decline and a cancellation process that is as simple as signing up.

Relevance to training and awareness

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 a Senior Vice President and a Vice President.
Published
25 Sep 2025

Original amount 2,500,000,000 USD, converted at the ECB reference rate of 25 Sep 2025.

Checked against the official source on 27 Sep 2026 · Version 2 · Direct link

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24 Sep 2025 Giant Manufacturing Co. Ltd.CBP detains bicycles from Giant Manufacturing over forced labour USAForced and child 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.

What organisations can take from it

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

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

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22 Sep 2025 ShapeShift AGOFAC: USD 750,000 settlement with ShapeShift over crypto exchanges with users in sanctioned countries USABreaches of sanctions and embargoes €636,618

Crypto exchange ShapeShift AG, incorporated in Switzerland and operated from Denver, Colorado, is paying USD 750,000 under a settlement with OFAC for apparent violations of multiple sanctions programmes. According to OFAC's findings, between December 2016 and October 2018 ShapeShift exchanged digital assets worth USD 12,570,956 with users in Cuba, Iran, Sudan and Syria in 17,183 instances, although IP addresses revealed their location. The company introduced a sanctions compliance programme only after receiving an OFAC subpoena. OFAC treated the apparent violations as non-egregious and not voluntarily self-disclosed; the base penalty was USD 39,515,000. The low settlement amount reflects the fact that ShapeShift has ceased operations and has limited assets. Source: U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC), enforcement release "ShapeShift AG Settles with OFAC for $750,000 Related to Apparent Violations of Multiple Sanctions Programs", 22 September 2025, https://ofac.treasury.gov/media/934641/download?inline; summarised in our own words.

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. § 515.201(b) (39); Iranian Transactions and Sanctions Regulations, 31 C.F.R. § 560.204 (16.839); Sudanese Sanctions Regulations, 31 C.F.R. § 538.205 (33); Syrian Sanctions Regulations, 31 C.F.R. § 542.207 (272); Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
22 Sep 2025

Original amount 750,000 USD, converted at the ECB reference rate of 22 Sep 2025.

Checked against the official source on 28 Sep 2026 · Version 3 · 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 USAInformation duties in online retail €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.

What organisations can take from it

Cancellations received must be reliably implemented in the systems – continuing to charge customers is a separate violation.

Relevance to training and awareness

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.

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17 Sep 2025 Shinhan Securities Co. Ltd.Shinhan Securities: 212,500 USD for 127 wash trades in crude oil futures on NYMEX USAMarket abuse and insider dealing €179,522

Between March 2023 and February 2024 a trader at the Korean financial services firm placed near-simultaneous opposing orders for accounts with the same beneficial owner, so that 127 trades in 440 crude oil futures (around 33.5 million USD) offset each other, some of them against orders from traders on other desks of the firm. The CFTC (U.S. Commodity Futures Trading Commission) treated this as prohibited wash sales and non-competitive trades and, in a settlement, imposed a civil monetary penalty of 212,500 USD and a cease-and-desist order; it granted a 20% reduction for excellent cooperation. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

Trade surveillance must catch trades in which orders from different accounts or desks of the same firm meet – such self-matches are quickly treated as wash trades.

Relevance to training and awareness

Prohibition of wash trades and self-matching between a firm's own accounts and desks

Authority / court
U.S. Commodity Futures Trading Commission (CFTC)
Area of law
Capital markets and financial supervision · Market abuse and insider dealing
Legal basis
Section 4c(a)(1) und (2)(A) Commodity Exchange Act; CFTC Regulation 1.38(a)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Culpability
intentional
Mitigating circumstances
Excellent cooperation with the Division of Enforcement (20% reduction of the penalty); the CFTC also acknowledged the company's representations regarding its remedial measures.
Published
17 Sep 2025

Original amount 212,500 USD, converted at the ECB reference rate of 17 Sep 2025.

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

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9 Sep 2025 Flatiron Futures Traders, LLCFlatiron Futures Traders: 200,000 USD for spoofing in E-mini futures USAMarket abuse and insider dealing €170,300

The CFTC imposed a fine of 200,000 USD on the Illinois trading firm. Measures against individuals are not set out here. From May to December 2022, orders were placed for Flatiron in E-mini S&P 500 and E-mini Nasdaq 100 futures on the CME that were intended to be cancelled before execution, so that the genuine orders on the opposite side were filled faster, in larger quantities or at better prices. The spoof orders exceeded the genuine orders in contract volume by a ratio of five to one. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

Trading firms are liable for their traders' spoofing; cancellation ratios and one-sided order patterns belong in ongoing surveillance.

Relevance to training and awareness

Recognising and preventing spoofing in proprietary trading

Authority / court
U.S. Commodity Futures Trading Commission (CFTC)
Area of law
Capital markets and financial supervision · Market abuse and insider dealing
Legal basis
Section 4c(a)(5)(C) Commodity Exchange Act (7 U.S.C. § 6c(a)(5)(C))
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Culpability
intentional
Liability of senior managers
Measures against individuals are not set out here.
Published
9 Sep 2025

Original amount 200,000 USD, converted at the ECB reference rate of 9 Sep 2025.

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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 USA, CAWorking time €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.

What organisations can take from it

In the restaurant trade, breaks must be actively scheduled and documented – being on call for guests during the break turns it into working time.

Relevance to training and awareness

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
Measures against individuals are not reported here.

Original amount 680,238 USD, converted at the ECB reference rate of 4 Sep 2025.

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

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3 Sep 2025 Fracht FWO Inc.Freight forwarder Fracht FWO chartered blocked Venezuelan airline with Mahan Air jet USABreaches of sanctions and embargoes €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.

What organisations can take from it

Urgent customer orders never justify skipping sanctions screening of carriers and of the aircraft or vessels used.

Relevance to training and awareness

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.

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 USAWaste and hazardous substances €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.

What organisations can take from it

When a crew member reports misconduct to management, the company must intervene immediately; otherwise it is liable for the continued pollution.

Relevance to training and awareness

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.

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

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19 Aug 2025 Allied Stone Inc.Allied Stone: 12.4 million USD – Chinese quartz declared as marble or glass USACustoms €10.6m

The Dallas-based supplier of countertops allegedly declared Chinese quartz surface products between 2018 and 2023 as goods subject to lower duties, such as marble or crystallised glass, and evaded anti-dumping and countervailing duties, including by using third parties as importers of record. The settlement of 12.4 million USD (a joint payment with a further settling party) resolves a whistleblower lawsuit.

What organisations can take from it

Do not rely on third parties acting as importer – you remain liable for the correct description of the goods; customs responsibility cannot be outsourced.

Relevance to training and awareness

Description and classification of goods subject to anti-dumping duties

Authority / court
U.S. Department of Justice, Civil Division, und U.S. Attorney’s Office Northern District of Texas
Area of law
Sanctions and export control · Customs
Legal basis
False Claims Act, 31 U.S.C. §§ 3729 ff. (Vergleich; Haftung nicht festgestellt)
Action
Other
Status of proceedings
final
Sector
Construction and real estate
Liability of senior managers
Measures against individuals are not reported here.
Published
19 Aug 2025

Original amount 12,400,000 USD, converted at the ECB reference rate of 19 Aug 2025.

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

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14 Aug 2025 Healthplex, Inc.Healthplex: 2 million USD – phishing incident not reported to supervisor for months USA, NYIncident reporting obligations €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.

What organisations can take from it

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.

Relevance to training and awareness

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.

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 USA, NYCustomer due diligence €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.

What organisations can take from it

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.

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 USABribery of public officials €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.

What organisations can take from it

Employees of state-owned banks are public officials – sales commissions paid to them are bribes, even if they are booked as marketing.

Relevance to training and awareness

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.

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 USAOther €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.

What organisations can take from it

Companies that pass controlled defence data to service providers must check their authorisation – self-disclosure and cooperation significantly reduce the consequences.

Relevance to training and awareness

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 USAExport control and dual-use goods €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.

What organisations can take from it

Include cover names and known aliases of listed customers in screening; sales and compliance must escalate indications of military end users.

Relevance to training and awareness

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.

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

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15 Jul 2025 Interactive Brokers LLCOFAC: USD 11.8 million settlement with Interactive Brokers over services for customers in sanctioned jurisdictions and blocked persons USABreaches of sanctions and embargoes €10.1m

Online broker Interactive Brokers LLC of Greenwich, Connecticut, is paying USD 11,832,136 under a settlement with OFAC for apparent violations of multiple sanctions programmes. According to OFAC's findings, between July 2016 and January 2024 the company provided brokerage and investment services to persons in Iran, Cuba, Syria and Crimea, processed trades in securities covered by the Chinese Military-Industrial Complex programme, carried out transactions involving blocked persons under several programmes and made prohibited new investment in Russia; 12,367 transactions were involved in total. OFAC treated the apparent violations as non-egregious and voluntarily self-disclosed and credited significant remediation and cooperation; the base penalty was USD 60,130,059. Source: U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC), enforcement release "Interactive Brokers LLC Settles with OFAC for $11,832,136 Related to Apparent Violations of Multiple Sanctions Regulations", 15 July 2025, https://ofac.treasury.gov/media/934501/download?inline; summarised in our own words.

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
E.O. 13685 § 1(a)(iii), E.O. 14024 §§ 1, 4(a), E.O. 14071 § 1(a)(i); 31 C.F.R. § 515.201 (Kuba), §§ 542.201, 542.207 (Syrien), § 560.204 (Iran), § 583.201 (Global Magnitsky), § 586.201 (Chinese Military-Industrial Complex), § 587.201 (Russian Harmful Foreign Activities), § 591.201 (Venezuela); Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
15 Jul 2025

Original amount 11,832,136 USD, converted at the ECB reference rate of 15 Jul 2025.

Checked against the official source on 28 Sep 2026 · Version 3 · 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 USA, NYSuspicious activity reports €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.

What organisations can take from it

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.

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2 Jul 2025 Key Holding, LLCLogistics company Key Holding: Colombian subsidiary organised 36 shipments to Cuba USABreaches of sanctions and embargoes €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.

What organisations can take from it

After an acquisition, roll out the sanctions compliance programme to the new foreign subsidiary immediately – the Cuba embargo applies to US-controlled subsidiaries worldwide.

Relevance to training and awareness

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.

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 USA, CACookies and tracking €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.

What organisations can take from it

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.

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

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26 Jun 2025 NUWAY Alliance, Inc.NUWAY Alliance: USD 18.5m over payments to Medicaid patients and double billing USAGifts, hospitality and benefits €15.8m

The Minnesota provider of outpatient addiction treatment pays USD 18,500,000 to resolve False Claims Act allegations and entered into a five-year Corporate Integrity Agreement with HHS-OIG. According to the US Attorney's Office, from January 2019 to February 2025 NUWAY compensated Medicaid patients for attending intensive outpatient treatment and also billed services in which the same period of time was counted twice. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

Cash or in-kind incentives to patients for using reimbursable services are prohibited kickbacks under US law.

Relevance to training and awareness

Incentives to patients for using reimbursable services

Authority / court
U.S. Attorney's Office, District of Minnesota (U.S. Department of Justice)
Area of law
Bribery and corruption · Gifts, hospitality and benefits
Legal basis
False Claims Act; Anti-Kickback Statute
Action
Other
Status of proceedings
final
Sector
Healthcare
Published
26 Jun 2025

Original amount 18,500,000 USD, converted at the ECB reference rate of 26 Jun 2025.

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

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25 Jun 2025 Harman International Industries, Inc.OFAC: USD 1.45 million settlement with Harman over diversion of products to Iran via a UAE distributor USABreaches of sanctions and embargoes €1.25m

Audio electronics group Harman International Industries, Inc. of Connecticut is paying USD 1,454,145 under a settlement with OFAC for eleven apparent violations of the Iran sanctions. According to OFAC's findings, from May 2018 to October 2020 its long-standing distributor in the United Arab Emirates sold Harman products to customers in Iran with the knowledge and support of 13 UK-based employees of its US subsidiary Harman Professional, Inc.; their conduct is attributable to Harman. OFAC treated the apparent violations as egregious but voluntarily self-disclosed; the base penalty was USD 2,077,350. Harman satisfies USD 400,000 of the settlement amount by investing in additional sanctions controls. OFAC signed the settlement agreement on 25 June 2025 and published it on 8 July 2025. Source: U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC), enforcement release "Harman International Industries, Inc. Settles with OFAC for $1,454,145 Related to Apparent Violations of Iranian Transactions and Sanctions Regulations", 8 July 2025, https://ofac.treasury.gov/media/934471/download?inline; summarised in our own words.

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. § 560.204(a) (elf mutmaßliche Verstöße); Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A
Action
Fine
Status of proceedings
final
Sector
Manufacturing and mechanical engineering
Published
8 Jul 2025

Original amount 1,454,145 USD, converted at the ECB reference rate of 25 Jun 2025.

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

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16 Jun 2025 Unicat Catalyst Technologies, LLCCatalyst manufacturer Unicat supplied Iran and blocked Venezuelan company USABreaches of sanctions and embargoes €3.35m

In 2016–2021, the Texas supplier of catalysts for refineries and steelworks supplied products and advice to customers in Iran via 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.

What organisations can take from it

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
Measures against individuals are not reported here.
Published
16 Jun 2025

Original amount 3,882,797 USD, converted at the ECB reference rate of 16 Jun 2025.

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

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12 Jun 2025 GVA Capital Ltd.OFAC: USD 216 million penalty on GVA Capital over managing an investment for a sanctioned oligarch USABreaches of sanctions and embargoes €186.3m

OFAC has imposed the statutory maximum penalty of USD 215,988,868 on San Francisco venture capital firm GVA Capital Ltd. by way of a Penalty Notice. According to OFAC's findings, between April 2018 and May 2021 GVA Capital knowingly managed an investment for a sanctioned Russian oligarch despite knowing of his blocked status, working with a relative who acted as his proxy. The company also failed to comply fully with an OFAC subpoena for 28 months. OFAC treated the violations as egregious and not voluntarily self-disclosed. The Penalty Notice was preceded by Pre-Penalty Notices dated 13 September 2023 and 22 August 2024. The publication does not mention any pending review. Source: U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC), enforcement release "OFAC Imposes $215,988,868 Penalty on GVA Capital Ltd. for Violating Ukraine/Russia-Related Sanctions and Reporting Obligations", 12 June 2025, https://ofac.treasury.gov/media/934366/download?inline; summarised in our own words.

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. §§ 589.201(a)(3), 589.201(b)(1), 589.213(a); Reporting, Procedures and Penalties Regulations, 31 C.F.R. § 501.602 (28 Verstöße, Subpoena); Penalty Notice nach 31 C.F.R. § 589.703 und den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
12 Jun 2025

Original amount 215,988,868 USD, converted at the ECB reference rate of 12 Jun 2025.

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

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30 May 2025 Adidas America Inc.Adidas America: USD 235,000 OSHA settlement over persisting fall hazards USAWorkplace safety and accidents €207,249

Adidas America reached a settlement with the US Department of Labor for penalties of 235,000 USD after OSHA, during a 2024 follow-up inspection at a warehouse in New York State, found the missing guardrails and unsafe ladder already cited in 2021 still uncorrected and identified a further unsafe ladder. The company must introduce a safety and health management programme at sites in New York, New Jersey and Puerto Rico, retrain employees on fall hazards, assess fall risks at each site and stop using overhead storage areas. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

Cited deficiencies must be demonstrably corrected – if a follow-up inspection finds the same issues, the case becomes considerably more expensive.

Relevance to training and awareness

Following up on cited health and safety deficiencies

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
Occupational Safety and Health Act (Absturzsicherung, Leitern)
Action
Fine
Status of proceedings
final
Sector
Retail and e-commerce
Repeat case
yes
Published
4 Jun 2025

Original amount 235,000 USD, converted at the ECB reference rate of 30 May 2025.

Checked against the official source on 3 Oct 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 USAOther €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.

What organisations can take from it

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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21 May 2025 GoDaddy Inc.FTC: GoDaddy must set up an information security programme after hosting security gaps USASecurity measures and risk management Order

According to the Federal Trade Commission (FTC, the US consumer protection authority), the web host did not use multi-factor authentication for its hosting services, monitored security threats inadequately and did not secure connections to customer data, yet advertised “award-winning security”. The final order prohibits false statements about security and requires a comprehensive information security programme and regular reviews by independent assessors.

What organisations can take from it

Be able to prove basics such as MFA and threat monitoring before advertising security – otherwise the advertising promise itself becomes the violation.

Relevance to training and awareness

MFA, monitoring and honest security promises

Authority / court
Federal Trade Commission (FTC)
Area of law
Information security and cyber · Security measures and risk management
Legal basis
Section 5 FTC Act
Action
Order
Status of proceedings
final
Sector
Telecoms, IT and software
Published
21 May 2025

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

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14 May 2025 Norfolk Southern Railway CompanyNorfolk Southern: EPA fine for locomotives without valid emissions certification USAEmissions and permits €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.

What organisations can take from it

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.

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

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12 May 2025 Fostermation Inc.Fostermation: USD 64,892 for child labour and machine guarding failures USAWorkplace safety and accidents €58,430

After a 16-year-old lost a thumb tip on a forming machine at metal components maker Fostermation in Meadville (Pennsylvania) in May 2024, the Wage and Hour Division and OSHA found breaches of child labour regulations and six serious and one other health and safety violation, including missing machine guards and deficient lockout/tagout procedures. The company paid 50,192 USD in civil money penalties for the child labour violations and 14,700 USD under a settlement with OSHA, a total of 64,892 USD. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

Minors must not operate hazardous forming machines – work schedules for young workers need a separate check against prohibited tasks.

Relevance to training and awareness

Deploying minors on hazardous machinery

Authority / court
U.S. Department of Labor – Wage and Hour Division (WHD) und Occupational Safety and Health Administration (OSHA)
Area of law
Health and safety and employment law · Workplace safety and accidents
Legal basis
Bundesrechtliche Kinderarbeitsvorschriften (Vollzug durch die Wage and Hour Division); OSHA-Standards zu Maschinenschutz und Lockout/Tagout
Action
Fine
Status of proceedings
final
Sector
Steel and metals
Published
12 May 2025

Original amount 64,892 USD, converted at the ECB reference rate of 12 May 2025.

Checked against the official source on 3 Oct 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 USA, CACookies and tracking €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.

What organisations can take from it

A consent management platform does not relieve companies of responsibility: check regularly whether opt-outs are actually implemented technically.

Relevance to training and awareness

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.

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 USAOther €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 employee received 1.512 million USD as a whistleblower.

What organisations can take from it

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 28 Sep 2026 · Version 2 · Direct link

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28 Apr 2025 Gilead Sciences, Inc.Gilead: 202 million USD – speaker programmes with fees, luxury meals and travel USAGifts, hospitality and benefits €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.

What organisations can take from it

Selecting speakers by prescription volume turns continuing education into bribery – selection criteria and hospitality limits must be documented.

Relevance to training and awareness

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.

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 USA, NYCustomer due diligence €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.

What organisations can take from it

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 USAForced and child labour 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)).

What organisations can take from it

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
Sources

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

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25 Mar 2025 Evolutions Flooring Inc.Evolutions Flooring: 8.1 million USD for false manufacturer and origin information on wood flooring USACustoms €7.48m

The Californian importer of multilayered wood flooring allegedly provided false information on the manufacturer and country of origin from 2019 to 2022, thereby evading anti-dumping, countervailing and Section 301 duties on Chinese goods. The settlement of 8.1 million USD is a joint payment by all settling parties and is based on the ability to pay.

What organisations can take from it

State the actual manufacturer and actual country of origin in customs declarations; false information used to evade anti-dumping, countervailing or Section 301 duties can be pursued as customs fraud.

Relevance to training and awareness

Manufacturer and origin information in customs declarations

Authority / court
U.S. Department of Justice, Civil Division, und U.S. Attorney’s Office Central District of California
Area of law
Sanctions and export control · Customs
Legal basis
False Claims Act, 31 U.S.C. §§ 3729 ff. (Vergleich; Haftung nicht festgestellt)
Action
Other
Status of proceedings
final
Sector
Construction and real estate
Mitigating circumstances
Settlement amount based on the ability to pay of the settling parties.
Liability of senior managers
Measures against individuals are not reported here.
Published
25 Mar 2025

Original amount 8,100,000 USD, converted at the ECB reference rate of 25 Mar 2025.

Checked against the official source on 28 Sep 2026 · Version 2 · 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 USAEmissions and permits €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.

What organisations can take from it

Manipulated test data in approval procedures lead to penalties that threaten a company's existence and to market bans; testing processes need independent controls.

Relevance to training and awareness

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.

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 USA, CAData subject rights and transparency €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.

What organisations can take from it

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.

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 USAOther €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.

What organisations can take from it

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.

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

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31 Jan 2025 Brink’s Global Services USA, Inc.FinCEN: USD 37 million against Brink's for cash shipments without an AML programme USAInternal controls €35.6m

FinCEN imposed a civil money penalty of USD 37 million on Brink’s Global Services USA, Inc. From October 2018 to October 2020 the company transported cash from Mexico to third parties in the United States and Spain, thereby acting as a money services business (MSB), without registering with FinCEN, setting up an AML programme or filing suspicious activity reports; the shipments were equivalent to around USD 800 million. USD 20 million that Brink’s pays to the DOJ under a non-prosecution agreement is credited against the penalty; USD 17 million is payable to FinCEN. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

Anyone moving cash across borders for third parties must check whether this triggers registration and reporting duties as a money services business.

Relevance to training and awareness

Registration and reporting duties for cash transport and money transmission

Authority / court
Financial Crimes Enforcement Network (FinCEN), U.S. Department of the Treasury
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
31 U.S.C. § 5330 und § 5318(h)(1), (g); 31 C.F.R. §§ 1022.380, 1022.210 sowie Pflicht zu Verdachtsmeldungen nach 31 C.F.R. Part 1022
Action
Fine
Status of proceedings
final
Sector
Transport, logistics and shipping
Mitigating circumstances
FinCEN took into account that the company cooperated with the authority and agreed to toll the statute of limitations.
Published
6 Feb 2025

Original amount 37,000,000 USD, converted at the ECB reference rate of 31 Jan 2025.

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

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24 Jan 2025 Pfizer Inc. (für die Tochter Biohaven Pharmaceutical Holding Company Ltd.)Pfizer/Biohaven: USD 59.7m over speaker fees and lavish meals for doctors USAGifts, hospitality and benefits €57.1m

Pfizer pays USD 59,746,277 on behalf of its subsidiary Biohaven to resolve False Claims Act and Anti-Kickback Statute allegations relating to the period before the acquisition; about USD 50.2 million goes to the federal government and about USD 9.5 million to state Medicaid programmes. From March 2020 to September 2022 Biohaven allegedly gave selected doctors speaker fees and meals at expensive restaurants to encourage prescriptions of the migraine drug Nurtec ODT; some events were attended repeatedly by the same doctors or by spouses, relatives and practice colleagues with no educational need.

What organisations can take from it

In acquisitions, the target's speaker programmes and payments to doctors belong in due diligence – the liability passes to the buyer.

Relevance to training and awareness

Speaker programmes: selection of speakers, repeat attendance, hospitality

Authority / court
U.S. Department of Justice (Civil Division; USAO Western District of New York)
Area of law
Bribery and corruption · Gifts, hospitality and benefits
Legal basis
False Claims Act; Anti-Kickback Statute
Action
Other
Status of proceedings
final
Sector
Chemicals and pharmaceuticals
Employees
10,000 or more
Published
24 Jan 2025

Original amount 59,746,277 USD, converted at the ECB reference rate of 24 Jan 2025.

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

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24 Jan 2025 Fantasia Trading LLC, Power Mobile Life LLC und Smart Innovation, LLC (Vertrieb der Marke eufy)eufy cameras: 450,000 USD in New York over unencrypted video streams USA, NYSecurity measures and risk management Fine

The New York Attorney General's office concluded an Assurance of Discontinuance with three US distribution companies of the eufy home security brand. Contrary to advertising promising privacy and end-to-end encryption, the cameras' video transmissions were in part not end-to-end encrypted and in part not encrypted at all, a live video stream could in some cases be accessed without authentication via the relevant URL, and testing processes that could have detected these vulnerabilities were lacking. The companies allegedly pay 450,000 USD in penalties and costs and must regularly substantiate that the manufacturer maintains an information security programme, secure software development, vulnerability management with penetration testing and encryption of the videos.

What organisations can take from it

A company that advertises encryption and privacy must be able to back this up with regular security testing – even as a distributor of a manufacturer's products.

Relevance to training and awareness

Substantiating security claims in advertising; security testing of connected devices

Missing or inadequate training played a role in the decision.

Authority / court
Office of the New York State Attorney General (Bureau of Internet & Technology)
Area of law
Information security and cyber · Security measures and risk management
Legal basis
New York Executive Law § 63(12); New York General Business Law §§ 349, 350
Action
Fine
Status of proceedings
final
Sector
Retail and e-commerce
Published
28 Jan 2025

Checked against the official source on 4 Oct 2026 · Direct link

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23 Jan 2025 C.R. Bard, Inc.; Liberator Medical Supply, Inc.; Liberator Holdings; Rochester Medical CorporationC.R. Bard: USD 17m over discounts and free samples for urology practices USAGifts, hospitality and benefits €16.3m

Bard and three affiliated companies pay USD 17 million to resolve allegations under the federal False Claims Act and several state statutes. Between 2016 and February 2020 they allegedly gave urology practices discounts, excessive free samples and savings on office supplies so that they would prescribe intermittent catheters by default using Bard's own “Link” prescription form; no liability was determined.

What organisations can take from it

Free samples and discounts must never be linked to prescribing routes that benefit one's own sales.

Relevance to training and awareness

Free samples and discounts in medical device sales

Authority / court
U.S. Attorney's Office, Northern District of Georgia (U.S. Department of Justice)
Area of law
Bribery and corruption · Gifts, hospitality and benefits
Legal basis
False Claims Act; Anti-Kickback Statute (42 U.S.C. § 1320a-7b); False-Claims-Gesetze mehrerer Bundesstaaten
Action
Other
Status of proceedings
final
Sector
Healthcare
Published
23 Jan 2025

Original amount 17,000,000 USD, converted at the ECB reference rate of 23 Jan 2025.

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

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23 Jan 2025 PayPal, Inc.NYDFS: $2 million against PayPal over untrained teams and missing MFA USA, NYSecurity measures and risk management €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.

What organisations can take from it

Anyone changing data flows must know the security processes – training development teams is part of cyber defence.

Relevance to training and awareness

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.

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

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17 Jan 2025 HF Sinclair Navajo Refining LLCHF Sinclair Navajo Refining: USD 35m for air violations at Artesia refinery USAEmissions and permits €34m

Under a consent decree with the EPA, the US Department of Justice and the New Mexico Environment Department, HF Sinclair Navajo Refining will allegedly pay a total of 35,000,000 USD for its refinery in Artesia (New Mexico): a civil penalty of 33,916,450 USD for excess emissions of, among others, benzene, volatile organic compounds, nitrogen oxides and sulphur dioxide, and 1,083,550 USD for breaches of a 2002 settlement; the civil penalty is split between the federal government and New Mexico. In addition, measures estimated at USD 137m are required, including real-time air monitors at the fenceline and in the town with publicly available results, and a flare gas recovery system. The authority allegedly made the findings set out here; this account is not based on a final judgment. The decision is not final.

What organisations can take from it

Fenceline monitoring obligations require documented root cause analyses and corrective action as soon as action levels are exceeded.

Relevance to training and awareness

Fenceline emission monitoring

Authority / court
U.S. Environmental Protection Agency (EPA) / U.S. Department of Justice mit New Mexico Environment Department (U.S. District Court, District of New Mexico)
Area of law
Environment and sustainability · Emissions and permits
Legal basis
Clean Air Act (NESHAP für Erdölraffinerien und Benzolabfälle, NSPS, Title-V-Genehmigung); New Mexico Air Quality Control Act; Consent Decree von 2002
Action
Fine
Status of proceedings
unknown
Sector
Energy and utilities
Repeat case
yes
Published
17 Jan 2025

Original amount 35,000,000 USD, converted at the ECB reference rate of 17 Jan 2025.

Checked against the official source on 4 Oct 2026 · Direct link

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17 Jan 2025 Equifax Inc. und Equifax Information Services LLCCFPB: Equifax pays 15 million USD over flawed handling of credit report disputes USAConsumer protection and online retail €14.6m

According to the CFPB, Equifax did not properly reinvestigate disputes about credit report entries, allowed deleted entries to be reinserted, informed consumers inadequately of the results and did not block entries resulting from identity theft as required (Fair Credit Reporting Act). The company also sold inaccurate credit scores after test code had been introduced into a production server; the order imposes a fine of 15 million USD. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

Data corrections must be lasting, and software changes may only reach production systems after testing.

Relevance to training and awareness

Dispute handling and change management for credit bureau data

Authority / court
Consumer Financial Protection Bureau (CFPB)
Area of law
Consumer protection and online retail
Legal basis
Fair Credit Reporting Act (15 U.S.C. §§ 1681c, 1681e, 1681i); Consumer Financial Protection Act of 2010, §§ 1031, 1036
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
17 Jan 2025

Original amount 15,000,000 USD, converted at the ECB reference rate of 17 Jan 2025.

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

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17 Jan 2025 Stericycle, Inc.Stericycle: USD 9.5m over failures in hazardous waste transport and manifests USAWaste and hazardous substances €9.23m

Under a court settlement (Stipulation and Order of Settlement) with the US Department of Justice and the EPA, Stericycle will pay a civil penalty of 9,500,000 USD for RCRA violations in its hazardous waste transport, storage and disposal business, which it operated until April 2020. The company lost track of shipments, delivered waste without the required manifests or to facilities not chosen by the customer, stored it too long at transfer facilities and failed to submit thousands of manifests to the EPA's e-Manifest system on time. According to the EPA, it is the first judicial action to enforce the e-Manifest requirements. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

Complete manifests and timely electronic reporting are separate, enforceable duties for hazardous waste, not mere formalities.

Relevance to training and awareness

Manifests and record-keeping duties for hazardous waste

Authority / court
U.S. Environmental Protection Agency (EPA) / U.S. Department of Justice (U.S. District Court, Southern District of New York)
Area of law
Environment and sustainability · Waste and hazardous substances
Legal basis
Resource Conservation and Recovery Act (RCRA), 42 U.S.C. § 6901 ff., e-Manifest-Vorschriften
Action
Fine
Status of proceedings
unknown
Sector
Other
Published
17 Jan 2025

Original amount 9,500,000 USD, converted at the ECB reference rate of 17 Jan 2025.

Checked against the official source on 3 Oct 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 USABreaches of sanctions and embargoes €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.

What organisations can take from it

Spare parts and software unlock codes for machines already delivered are also services relevant to sanctions – end customers behind dealers must be known.

Relevance to training and awareness

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.

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 USAOrganisational requirements €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.

What organisations can take from it

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.

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

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16 Jan 2025 Block, Inc. (Cash App)CFPB: Block (Cash App) must pay at least 130 million USD over fraud handling USAConsumer protection and online retail €53.5m

The CFPB found that Block did not effectively prevent and address fraud on Cash App, handled disputes and chargebacks unfairly, did not provide effective customer service, misled users about protection against unauthorised transfers and breached error-resolution duties under the Electronic Fund Transfer Act and Regulation E. The order imposes a fine of 55 million USD and requires 75 million USD for redress, which may rise to up to 120 million USD (up to 175 million USD in total). The authority allegedly made the findings set out here; this account is not based on a final judgment. The amount field records only the civil monetary penalty.

What organisations can take from it

Payment services must be reachable for fraud reports and investigate them on time – security promises in advertising are measured against this.

Relevance to training and awareness

Handling fraud reports and disputes in payment apps

Authority / court
Consumer Financial Protection Bureau (CFPB)
Area of law
Consumer protection and online retail
Legal basis
Consumer Financial Protection Act of 2010 (12 U.S.C. §§ 5531, 5536); Electronic Fund Transfer Act und Regulation E (12 C.F.R. §§ 1005.6, 1005.7, 1005.11, 1005.13, 1005.18)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
16 Jan 2025

Original amount 55,000,000 USD, converted at the ECB reference rate of 16 Jan 2025.

Sources

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16 Jan 2025 Family International Realty LLCOFAC: USD 1.08 million settlement with Family International Realty over concealing properties of sanctioned oligarchs USABreaches of sanctions and embargoes €1.05m

Miami real estate company Family International Realty LLC is paying USD 1,076,923 jointly with a further settling party under a settlement with OFAC (joint payment) for 73 apparent violations of the Ukraine-/Russia-related sanctions. According to OFAC's findings, between 2018 and 2023 the company, in a wilful evasion scheme, transferred nominal ownership of three luxury condominiums belonging to two sanctioned Russian oligarchs to non-sanctioned relatives and their shell companies and continued to rent them out; the company earned around USD 182,442 in commissions and reimbursements. OFAC treated the apparent violations as egregious and not voluntarily self-disclosed; the base penalty equalled the statutory maximum of USD 30,080,709. USD 182,442 is deemed satisfied by a forfeiture payment to the DOJ. Source: OFAC enforcement release of 16 January 2025, https://ofac.treasury.gov/media/933941/download?inline; summarised in our own words.

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
E.O. 13685 §§ 2(a), 5(a), 6(a) (73 mutmaßliche Verstöße); Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A
Action
Fine
Status of proceedings
final
Sector
Construction and real estate
Liability of senior managers
Measures against individuals are not reported here.
Published
16 Jan 2025

Original amount 1,076,923 USD, converted at the ECB reference rate of 16 Jan 2025.

Checked against the official source on 28 Sep 2026 · Version 5 · Direct link

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16 Jan 2025 DoNotPay, Inc.FTC: “robot lawyer” DoNotPay pays 193,000 USD for untested AI promises USAAI systems €187,889

According to the complaint of the Federal Trade Commission (FTC, the US consumer protection authority), DoNotPay advertised its AI chatbot as “the world’s first robot lawyer” that could replace a human lawyer, without ever having tested its performance against lawyers or having it reviewed by legal professionals. The final settlement order (5–0 vote) prohibits such claims without evidence and requires 193,000 USD and notification of subscribers from 2021 to 2023 about the limitations of the legal features.

What organisations can take from it

Back performance claims for AI products with tests that prove exactly the advertised capability – “replaces the professional” is a verifiable promise.

Relevance to training and awareness

Substantiating advertising claims about AI capabilities

Authority / court
Federal Trade Commission (FTC)
Area of law
AI and digital regulation · AI systems
Legal basis
Section 5 FTC Act (irreführende Geschäftspraktiken)
Action
Order
Status of proceedings
final
Sector
Telecoms, IT and software
Published
11 Feb 2025

Original amount 193,000 USD, converted at the ECB reference rate of 16 Jan 2025.

Checked against the official source on 28 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 USAEmissions and permits €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.

What organisations can take from it

Certification data is evidence – companies that embellish test results risk their existence, loss of market access and criminal prosecution.

Relevance to training and awareness

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.

Sources

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15 Jan 2025 Donghai JA Solar Technology Co., Ltd.UFLPA list: solar manufacturer Donghai JA Solar Technology added USAForced and child labour 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.

What organisations can take from it

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

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 USAForced and child labour 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.

What organisations can take from it

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

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 USAWorkplace safety and accidents €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).

What organisations can take from it

In the event of a chemical release, a rehearsed emergency and evacuation plan determines how many employees come to harm.

Relevance to training and awareness

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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14 Jan 2025 Presto Automation Inc.SEC: “AI washing” – Presto Automation overstated the automation of its drive-thru AI USAAI systems Order

According to the Securities and Exchange Commission (SEC, the US securities regulator), the restaurant technology company, which was listed at the time, made misleading statements about its voice AI product “Presto Voice” from 2021 to 2023: it concealed that the speech recognition initially belonged to a third party and claimed that the AI eliminated the need for human order-taking, although the vast majority of orders required human intervention. The SEC issued a cease-and-desist order without a fine.

What organisations can take from it

Disclose in investor communications on AI how much human work is in the product and who owns the technology – exaggeration is a capital markets violation.

Relevance to training and awareness

Capital markets communication on AI products (“AI washing”)

Authority / court
U.S. Securities and Exchange Commission (SEC)
Area of law
AI and digital regulation · AI systems
Legal basis
Section 17(a)(2) Securities Act 1933; Section 13(a) Securities Exchange Act 1934
Action
Order
Status of proceedings
final
Sector
Telecoms, IT and software
Mitigating circumstances
No fine owing to cooperation and remedial measures.
Published
14 Jan 2025

Checked against the official source on 28 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 USAOrganisational requirements €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.

What organisations can take from it

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.

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

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13 Jan 2025 IntelliVision Technologies Corp.FTC: IntelliVision may no longer advertise facial recognition as “free of bias” USAAI systems Order

According to the complaint of the Federal Trade Commission (FTC, the US consumer protection authority), the provider of AI facial recognition claimed without sufficient evidence that its software was among the most accurate on the market and performed without gender or skin-colour bias; contrary to its advertising, it had not been trained on millions of faces, and there was no evidence for the claim that it could not be fooled by photos or videos. The final settlement order prohibits false statements on accuracy, demographic performance and spoofing detection, as well as such statements without reliable testing.

What organisations can take from it

Treat statements on the fairness and accuracy of an AI model as advertising claims – anyone promising “bias-free” must have tested performance for each population group.

Relevance to training and awareness

Verifiable statements on the accuracy and fairness of AI models

Authority / court
Federal Trade Commission (FTC)
Area of law
AI and digital regulation · AI systems
Legal basis
Section 5 FTC Act (irreführende Geschäftspraktiken)
Action
Order
Status of proceedings
final
Sector
Telecoms, IT and software
Published
13 Jan 2025

Checked against the official source on 28 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 USAMerger control €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.

What organisations can take from it

Until clearance, the buyer must not exert any influence on the target company's operations – integration teams need clear gun-jumping rules.

Relevance to training and awareness

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.

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

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7 Jan 2025 City of Boardman (Oregon)City of Boardman: 8,770 USD – water system's risk assessment was an empty template USACritical infrastructure €8,438

The U.S. Environmental Protection Agency (EPA, Region 10) imposed a civil penalty of 8,770 USD by consent agreement and final order on the City of Boardman (Oregon), whose drinking water system serves around 4,490 people. According to the EPA, the city had not prepared the risk and resilience assessment and emergency response plan required by the Safe Drinking Water Act on time and had not complied with a 2022 EPA order: at an inspection in April 2024 the assessment was an empty template, and the emergency response plan dated from 2005 and contained no cybersecurity section. The city admitted jurisdiction without admitting or denying the factual allegations and waived its right to appeal. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

Mandatory assessments of physical and cyber security must be substantively prepared and kept up to date – a template that has merely been certified does not meet the obligation.

Relevance to training and awareness

Actually prepare the risk and resilience assessment, including cybersecurity, and keep the emergency response plan current

Authority / court
U.S. Environmental Protection Agency (EPA), Region 10
Area of law
Information security and cyber · Critical infrastructure
Legal basis
Safe Drinking Water Act Section 1433(a) und (b) (42 U.S.C. § 300i-2) sowie Section 1414(g)(3)(A); Strafe nach Section 1414(g)(3)(B) (42 U.S.C. § 300g-3(g)(3)(B))
Action
Fine
Status of proceedings
final
Sector
Energy and utilities
Repeat case
yes
Published
7 Jan 2025

Original amount 8,770 USD, converted at the ECB reference rate of 7 Jan 2025.

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

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6 Jan 2025 Gemini Trust Company, LLCGemini Trust: 5 million USD over misleading statements to the CFTC USADisclosure and reporting obligations €4.8m

On a complaint by the CFTC, the federal court in New York ordered the New York trust company, in a consent order, to pay a fine of 5 million USD and imposed a permanent injunction. In 2017, in connection with the self-certification of a bitcoin futures contract that referenced an auction on Gemini, Gemini made statements to the CFTC, or omitted facts, that it should reasonably have known were false or misleading, for example on its prefunding requirement, self-trade prevention, fee rebates and trading volume and liquidity. These statements were material to the assessment of whether the contract was susceptible to manipulation. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

What a company tells the supervisor to assess a product must be complete and reliable; statements made by its representatives are attributed to it.

Relevance to training and awareness

Truthful statements to supervisory authorities

Authority / court
U.S. District Court for the Southern District of New York (auf Klage der CFTC)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Section 6(c)(2) Commodity Exchange Act (7 U.S.C. § 9(2))
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
13 Jan 2025

Original amount 5,000,000 USD, converted at the ECB reference rate of 6 Jan 2025.

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

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3 Jan 2025 GGL Projects, Inc. (Sitejabber)Sitejabber: review platform counted reviews before goods were received USAFake reviews 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.

What organisations can take from it

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
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31 Dec 2024 Grubhub Inc. und Grubhub Holdings Inc.FTC and Illinois: Grubhub pays 25 million USD over hidden delivery fees USAMisleading advertising and pricing €24.1m

The FTC and the Illinois Attorney General alleged that the delivery service misled customers about delivery costs and blocked their accounts and balances, promised drivers inflated earnings and listed restaurants without their consent. The court order sets a judgment of 140 million USD, suspended except for a payment of 24.8 million USD to the FTC; in addition, 200,000 USD goes to Illinois (25 million USD in total). The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

Platforms must show full final prices from the outset and may list partners only with their consent.

Relevance to training and awareness

Total price disclosure and earnings claims on platforms

Authority / court
Federal Trade Commission (FTC) und Attorney General of Illinois
Area of law
Consumer protection and online retail · Misleading advertising and pricing
Legal basis
Section 5 FTC Act; Restore Online Shoppers' Confidence Act; Impersonation Rule (16 C.F.R. Part 461); Illinois Consumer Fraud and Deceptive Business Practices Act (815 ILCS 505); Illinois Uniform Deceptive Trade Practices Act (815 ILCS 510)
Action
Disgorgement of profits
Status of proceedings
final
Sector
Media and online platforms
Published
17 Dec 2024

Original amount 25,000,000 USD, converted at the ECB reference rate of 31 Dec 2024.

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

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31 Dec 2024 SkyGeek Logistics, Inc.OFAC: USD 22,172 settlement with SkyGeek Logistics over shipments and refunds to designated aviation suppliers USABreaches of sanctions and embargoes €21,342

New York aviation products supplier SkyGeek Logistics, Inc. is paying USD 22,172 under a settlement with OFAC for six apparent violations of the Russia sanctions. According to OFAC's findings, between January and March 2024 the company sent four shipments worth USD 3,429.76 to two UAE-based companies and attempted two refunds totalling USD 17,511.63, although both had previously been added to the SDN List for their role in Russia's aerospace and technology sectors. Customers were initially not rescreened before refunds. OFAC treated the apparent violations as non-egregious and four of the six transactions as voluntarily self-disclosed; the base penalties totalled USD 27,715. Source: U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC), enforcement release "SkyGeek Logistics, Inc. Settles with OFAC for $22,172 for Apparent Violations of the Russian Harmful Foreign Activities Sanctions Regulations", 31 December 2024, https://ofac.treasury.gov/media/933866/download?inline; summarised in our own words.

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
Russian Harmful Foreign Activities Sanctions Regulations, 31 C.F.R. § 587.201 (sechs mutmaßliche Verstöße); Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A
Action
Fine
Status of proceedings
final
Sector
Retail and e-commerce
Published
31 Dec 2024

Original amount 22,172 USD, converted at the ECB reference rate of 31 Dec 2024.

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

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23 Dec 2024 MMM Holdings, LLCMMM Holdings: USD 15.2m over gift cards for Medicare plan enrolments USAGifts, hospitality and benefits €14.7m

The Puerto Rico Medicare Advantage provider pays USD 15,228,340 to resolve False Claims Act and Anti-Kickback Statute allegations and entered into a five-year Corporate Integrity Agreement with HHS-OIG. From January 2018 to December 2022 MMM allegedly gave gift cards to administrative assistants of medical practices so that they would get thousands of Medicare beneficiaries to enrol in an MMM plan; the resulting premium payments amounted to USD 6,091,336.

What organisations can take from it

Gifts to practice staff who advise insured patients are as sensitive as benefits to doctors.

Relevance to training and awareness

Gifts to practice staff who advise or refer patients

Authority / court
U.S. Attorney's Office, District of Puerto Rico; HHS Office of Inspector General (HHS-OIG)
Area of law
Bribery and corruption · Gifts, hospitality and benefits
Legal basis
False Claims Act; Anti-Kickback Statute
Action
Other
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
The company's cooperation and its implementation of internal controls were taken into account.
Published
23 Dec 2024

Original amount 15,228,340 USD, converted at the ECB reference rate of 23 Dec 2024.

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

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23 Dec 2024 FCA US LLCFCA US: USD 4.19m CARB settlement over emission controls in Ram ProMaster USA, CaliforniaEmissions and permits €2.01m

CARB reached a settlement of 4,185,820 USD with FCA US because model year 2014 to 2016 Ram ProMaster vehicles with a 3.0-litre diesel engine had an unapproved device that controlled emissions differently in real-world driving than in certification testing; according to CARB, almost 55 tonnes of excess nitrogen oxides were released. The civil penalty is 2,092,910 USD. An environmental project of the same amount, to slow cargo vessels, stays outside the amount field. The vehicles will be recalled. CARB had already taken action against FCA over similar allegations in 2019 and 2022. The authority allegedly made the findings set out here; this account is not based on a final judgment. The amount field records only the civil monetary penalty.

What organisations can take from it

Differences between test-bench and on-road behaviour of emission controls must be disclosed before certification.

Relevance to training and awareness

Disclosure of emission-relevant software and hardware

Authority / court
California Air Resources Board (CARB)
Area of law
Environment and sustainability · Emissions and permits
Legal basis
Luftqualitäts- und Fahrzeugemissionsvorschriften des California Air Resources Board
Action
Fine
Status of proceedings
final
Sector
Automotive
Repeat case
yes
Published
23 Dec 2024

Original amount 2,092,910 USD, converted at the ECB reference rate of 23 Dec 2024.

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

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20 Dec 2024 Marriott International, Inc. und Starwood Hotels & Resorts Worldwide LLCFTC: Marriott and Starwood must upgrade security after three data breaches affecting 344 million people USASecurity measures and risk management Order

According to the Federal Trade Commission (FTC, the US consumer protection authority), three attacks between 2014 and 2020 affected more than 344 million guests worldwide, including 5.25 million unencrypted passport numbers; one intrusion went undetected for 14 months. The FTC alleges inadequate password, access, firewall and segmentation controls, failure to patch, insufficient logging and too little MFA; the order finalised in December 2024 requires a security programme with annual certification to the FTC for 20 years, independent assessments every two years, data minimisation and a deletion option for US customers. In parallel, Marriott pays 52 million USD to 49 states and Washington, D.C.

What organisations can take from it

Review the security of acquired systems before and immediately after closing – an acquisition brings its legacy IT problems with it.

Relevance to training and awareness

Patching, network segmentation and MFA after company acquisitions

Authority / court
Federal Trade Commission (FTC)
Area of law
Information security and cyber · Security measures and risk management
Legal basis
Section 5 FTC Act
Action
Order
Status of proceedings
final
Sector
Other
Employees
10,000 or more
Published
20 Dec 2024

Checked against the official source on 28 Sep 2026 · Version 2 · 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 USABribery of public officials €53.5m

According to the SEC's findings, AAR paid sham commissions to public officials through intermediaries (a sales agent and a joint venture partner) 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.

What organisations can take from it

State-owned airlines are public contracting entities – scrutinise commissions to intermediaries in aircraft transactions rigorously.

Relevance to training and awareness

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.
Published
19 Dec 2024

Original amount 55,599,653 USD, converted at the ECB reference rate of 19 Dec 2024.

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

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19 Dec 2024 The Manitowoc Company, Inc.; Grove U.S. L.L.C.; Manitowoc Crane Group Germany GmbHManitowoc: USD 42.6m for cranes with uncertified diesel engines USAEmissions and permits €41m

Under a consent decree, crane maker Manitowoc and two subsidiaries will pay a civil penalty of 42,600,000 USD because, between 2014 and 2018, they allegedly sold cranes with at least 1,032 diesel engines that were covered neither by a valid EPA certificate of conformity nor by the transition programme for equipment manufacturers; reporting, bonding and labelling requirements were also breached. In addition, the companies will fund the repowering of a locomotive in the Sparrows Point area (Baltimore) with an engine meeting current emission standards. According to the EPA, the court approved the settlement in March 2025.

What organisations can take from it

Companies using transitional engine allowances must be able to allocate every installed unit – otherwise it counts as uncertified.

Relevance to training and awareness

Certification of engines in imported machinery

Authority / court
U.S. Environmental Protection Agency (EPA) / U.S. Department of Justice (U.S. District Court, Eastern District of Wisconsin)
Area of law
Environment and sustainability · Emissions and permits
Legal basis
Clean Air Act, Sections 203(a) und 213(d) (Mobile-Source-Vorschriften für Offroad-Dieselmotoren)
Action
Fine
Status of proceedings
final
Sector
Manufacturing and mechanical engineering
Published
19 Dec 2024

Original amount 42,600,000 USD, converted at the ECB reference rate of 19 Dec 2024.

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

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19 Dec 2024 Amazon.com Services LLCAmazon: company-wide OSHA settlement on ergonomics in logistics centres, USD 145,000 USAWorkplace safety and accidents €139,490

OSHA and Amazon.com Services entered into a company-wide settlement resolving ten cases over ergonomic hazards – such as lower back and other musculoskeletal disorders – arising from inspections at ten facilities since summer 2022, which were due to be tried before the Occupational Safety and Health Review Commission in 2025. Amazon will pay 145,000 USD, according to OSHA more than 90 per cent of the penalties assessed, and must assess ergonomic risks annually at fulfilment, sortation and delivery centres, evaluate and implement controls and resolve employee complaints through a dispute resolution process. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

Ergonomic risks in warehouse logistics are now pursued like conventional safety failings – with a duty to assess risks across all sites.

Relevance to training and awareness

Ergonomics and musculoskeletal strain in logistics

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 (Ergonomie-Beanstandungen)
Action
Fine
Status of proceedings
final
Sector
Retail and e-commerce
Employees
10,000 or more
Published
19 Dec 2024

Original amount 145,000 USD, converted at the ECB reference rate of 19 Dec 2024.

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

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18 Dec 2024 Córdoba Music Group LLCOFAC: USD 41,591 settlement with Córdoba Music Group over instrument shipments to Iran USABreaches of sanctions and embargoes €39,626

Californian musical instrument manufacturer Córdoba Music Group LLC is paying USD 41,591 under a settlement with OFAC for apparent violations of the Iran sanctions. According to OFAC's findings, between November 2019 and March 2022 the company made nine shipments of instruments and accessories worth USD 118,831 to a trading company in Dubai, knowing that the goods were destined for an Iranian distributor. According to OFAC, the company apparently did not realise, partly owing to a lack of compliance training, that indirect exports to Iran were prohibited. This came to light after the company was acquired by a new owner. OFAC treated the apparent violations as non-egregious and voluntarily self-disclosed; the base penalty was USD 59,416. Source: U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC), enforcement release "Córdoba Music Group LLC Settles with OFAC for $41,591 Related to Apparent Violations of the Iranian Transactions and Sanctions Regulations", 18 December 2024, https://ofac.treasury.gov/media/933726/download?inline; summarised in our own words.

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. § 560.204(a) (neun Lieferungen); Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A
Action
Fine
Status of proceedings
final
Sector
Other
Published
18 Dec 2024

Original amount 41,591 USD, converted at the ECB reference rate of 18 Dec 2024.

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

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18 Dec 2024 Rytr LLCFTC bans Rytr’s AI review generator – order set aside a year later USAFake reviews overturned

According to the complaint of the Federal Trade Commission (FTC, the US consumer protection authority), the AI writing service offered a “Testimonial & Review” feature that generated detailed customer reviews with entirely invented details from brief, generic input; individual users produced hundreds to tens of thousands of reviews with it. With the final settlement order (3–2 vote), the FTC prohibited Rytr from offering any service for generating reviews. On 22 December 2025, the FTC set the order aside again with Rytr’s consent (2–0 vote): the facts alleged in the complaint did not support a violation of Section 5 of the FTC Act, and the order unduly burdened AI innovation, contrary to the Trump Administration’s AI Executive Order and AI Action Plan.

What organisations can take from it

Take responsibility for the authenticity of AI-generated reviews you publish – in the Rytr case, the FTC ultimately saw no violation in merely offering an AI writing tool.

Authority / court
Federal Trade Commission (FTC)
Area of law
Consumer protection and online retail · Fake reviews
Legal basis
Section 5 FTC Act (Mittel zur Täuschung bereitgestellt)
Action
Order
Status of proceedings
overturned
Sector
Telecoms, IT and software
Published
18 Dec 2024

Checked against the official source on 28 Sep 2026 · Version 2 · 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 USADisclosure and reporting obligations €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.

What organisations can take from it

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.

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

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13 Dec 2024 C.H. Robinson International, Inc.C.H. Robinson: foreign subsidiaries transported Iranian and Cuban goods USABreaches of sanctions and embargoes €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.

What organisations can take from it

Connect acquired freight forwarders to central screening quickly; until then, interim controls on origin and carrier are needed.

Relevance to training and awareness

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.

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

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12 Dec 2024 Oroville HospitalOroville Hospital: USD 10.25m over admission bonuses for doctors and false billing USACommercial bribery €9.77m

The Californian hospital pays USD 10,250,000 (USD 9,518,954 to the federal government, USD 731,046 to the State of California) and entered into a five-year Corporate Integrity Agreement with HHS-OIG. The allegations were that it paid doctors who decided on inpatient admissions bonuses based on the number of patients admitted, billed medically unnecessary inpatient admissions and used false diagnosis codes for SIRS. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

Bonus schemes for doctors must not be linked to the number of admissions or referrals.

Relevance to training and awareness

Bonus schemes for doctors and referral incentives in hospitals

Authority / court
U.S. Attorney's Office, Eastern District of California (U.S. Department of Justice)
Area of law
Bribery and corruption · Commercial bribery
Legal basis
False Claims Act; Anti-Kickback Statute
Action
Other
Status of proceedings
final
Sector
Healthcare
Published
12 Dec 2024

Original amount 10,250,000 USD, converted at the ECB reference rate of 12 Dec 2024.

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

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5 Dec 2024 McKinsey and Company Africa (Pty) LtdMcKinsey Africa: USD 122.85m for bribery at two South African state-owned companies USABribery of public officials €116.6m

The South African subsidiary of McKinsey & Company entered into a three-year DPA with a penalty of USD 122,850,000; up to half is credited against payments to South African authorities. According to the Department, between at least 2012 and 2016 it obtained confidential information from two South African state-owned companies (logistics and energy) on consulting contracts and bid knowing that South African partner firms would pass part of their fees on to officials as bribes. According to the Department, the profit from the scheme was about USD 85 million.

What organisations can take from it

Local partner firms in consortia with state-owned enterprises need the same anti-corruption vetting as one's own intermediaries, including how their fees are used.

Relevance to training and awareness

Local partner firms and consortia as a bribery channel in public-sector consulting contracts

Missing or inadequate training played a role in the decision.

Authority / court
U.S. Department of Justice (Criminal Division, Fraud Section; USAO Southern District of New York)
Area of law
Bribery and corruption · Bribery of public officials
Legal basis
Foreign Corrupt Practices Act (FCPA): Verschwörung zum Verstoß gegen die Anti-Bribery-Vorschriften (Criminal Information, Southern District of New York)
Action
Fine
Status of proceedings
unknown
Sector
Other
Mitigating circumstances
Credit was given for immediate, proactive cooperation, reporting of discovered attempts to delete records, personnel consequences, additional anti-corruption training in Africa and a temporary halt to work for state-owned enterprises.
Liability of senior managers
Measures against individuals are not reported here.
Published
5 Dec 2024

Original amount 122,850,000 USD, converted at the ECB reference rate of 5 Dec 2024.

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

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26 Nov 2024 Evolv Technologies Holdings, Inc.FTC: Evolv to let schools exit contracts – alleged overstated advertising for AI weapons scanners USAAI systems Order

According to the complaint of the Federal Trade Commission (FTC, the US consumer protection authority), Evolv advertised that its AI-powered security scanners would detect all weapons, ignore harmless items and be more accurate and faster than metal detectors; according to the complaint, the devices at one school missed a knife in October 2022 that was used to stab a student. The settlement order filed together with the complaint at the federal court in Massachusetts is to allow schools with contracts from April 2022 to June 2023 to cancel and to prohibit unsubstantiated claims about detection performance, false alarms and staffing costs; according to the FTC case page, court approval was still pending in March 2025.

What organisations can take from it

Keep performance claims for safety-critical AI accurate – overstated claims become a contractual risk, and customers can be released from contracts based on them.

Relevance to training and awareness

Performance claims for AI security technology

Authority / court
Federal Trade Commission (FTC)
Area of law
AI and digital regulation · AI systems
Legal basis
Section 5 FTC Act; Stipulated Order for Permanent Injunction
Action
Order
Status of proceedings
unknown
Sector
Defence and security
Published
26 Nov 2024

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

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25 Nov 2024 Government Employees Insurance Company (GEICO)GEICO: 5 million USD from NYDFS over cyberattacks on quoting and claims portals USA, NYSecurity measures and risk management €4.76m

From late 2020 onwards, attackers obtained non-public data of New Yorkers, above all driver's licence numbers, in several incidents through publicly accessible web applications of the car insurer GEICO – including the quoting portal, the claims website and an interface. The New York State Department of Financial Services (NYDFS) found breaches of the cybersecurity regulation 23 NYCRR Part 500, including inadequate risk assessments, missing monitoring of user activity and incorrect compliance certifications for 2017 to 2021, and imposed a penalty of 5,000,000 USD. In parallel, GEICO pays a further 4,750,000 USD in a separate settlement with the New York Attorney General. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

After an incident it is not enough to close the one gap – all publicly accessible applications need to be reassessed, especially once the industry has been warned.

Relevance to training and awareness

Security of publicly accessible web applications; responding to industry alerts

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 §§ 500.2(b), 500.3(i) und (k), 500.5, 500.8(a), 500.9(a), 500.14(a), 500.17(b); Strafe nach New York Financial Services Law § 408
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
The NYDFS acknowledged the company's cooperation during the investigation and its substantial investment in remediating the shortcomings.
Published
25 Nov 2024

Original amount 5,000,000 USD, converted at the ECB reference rate of 25 Nov 2024.

Checked against the official source on 3 Oct 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 USADisclosure and reporting obligations €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.

What organisations can take from it

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.

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

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22 Nov 2024 Jindal Tubular USA LLCPipe mill Jindal Tubular: $442,815 settlement after fatal pipe collapse USAWorkplace safety and accidents €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.

What organisations can take from it

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 28 Sep 2026 · Version 2 · Direct link

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19 Nov 2024 Valenti's Bakery LLCNew Jersey bakery: OSHA proposes $385,221 because deficiencies allegedly remained after finger amputation USAWorkplace safety and accidents €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; according to OSHA, lockout/tagout procedures were still missing at the follow-up inspection in May 2024, and exit routes were blocked and fall edges unprotected. OSHA proposed penalties of $385,221 (including for failure to abate, 2 violations classified as wilful and 1 as repeat); the violations are alleged and may be contested.

What organisations can take from it

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.

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

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18 Nov 2024 BIT Mining Ltd. (vormals 500.com)BIT Mining (formerly 500.com): USD 10m for bribing Japanese officials USABribery of public officials €9.48m

The company entered into a three-year DPA; under the guidelines USD 54 million would have been appropriate, but because of a demonstrated inability to pay a penalty of USD 10 million was agreed, of which up to USD 4 million is credited against the SEC civil penalty. From 2017 to 2019 the company, then trading as 500.com, agreed to pay about USD 1.9 million to consultants, intended to reach Japanese officials as cash, travel, entertainment and gifts, in order to win an integrated resort bid in Japan; the payments were booked as consultancy fees under sham contracts. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

Anyone bidding for state concessions abroad must check consultancy and intermediary agreements for genuine services and for where the money goes.

Relevance to training and awareness

Consultancy agreements in foreign licensing and major project tenders

Authority / court
U.S. Department of Justice (Criminal Division, Fraud Section; USAO District of New Jersey)
Area of law
Bribery and corruption · Bribery of public officials
Legal basis
Foreign Corrupt Practices Act (FCPA): Verschwörung zum Verstoß gegen die Anti-Bribery- und Books-and-Records-Vorschriften sowie Verstoß gegen die Books-and-Records-Vorschriften (Criminal Information, District of New Jersey)
Action
Fine
Status of proceedings
final
Sector
Other
Mitigating circumstances
The penalty was capped at USD 10 million because of the company's financial condition; limited, reactive cooperation and remediation were credited (10% reduction off the bottom of the guidelines range).
Liability of senior managers
Measures against individuals are not set out here.
Published
18 Nov 2024

Original amount 10,000,000 USD, converted at the ECB reference rate of 18 Nov 2024.

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

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14 Nov 2024 American Life Insurance Company (ALICO)OFAC: USD 178,421 settlement with American Life Insurance Company over policies for Iranian government entities USABreaches of sanctions and embargoes €169,392

American Life Insurance Company (ALICO), a Delaware-based US insurer with global group and individual business, is paying USD 178,421 under a settlement with OFAC for apparent violations of the Iran sanctions. According to OFAC's findings, between February 2022 and August 2023 ALICO insured three policyholders in the United Arab Emirates that were owned or controlled by the Government of Iran and therefore blocked, including schools; in total 2,331 premiums and claims worth USD 446,077 were processed. Screening alerts were wrongly closed as false positives. OFAC treated the apparent violations as non-egregious and voluntarily self-disclosed; the base penalty was USD 223,038. Source: U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC), enforcement release "American Life Insurance Company Settles with OFAC for $178,421 Related to Apparent Violations of Iranian Transactions and Sanctions Regulations", 14 November 2024, https://ofac.treasury.gov/media/933596/download?inline; summarised in our own words.

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. §§ 560.204 (Dienstleistungsexport), 560.211 (gesperrtes Vermögen); Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
14 Nov 2024

Original amount 178,421 USD, converted at the ECB reference rate of 14 Nov 2024.

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

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13 Nov 2024 National Amusements, Inc.Cinema operator National Amusements: 250,000 USD over data breach and late notice USA, NYEmployee data €235,206

In December 2022 an attacker used an employee's stolen credentials to break into the systems of the cinema operator National Amusements because multi-factor authentication was not enforced for all access routes; data such as social security, passport and account numbers of 82,128 people was affected – according to the company, current and former employees and contractors – of whom 23,365 were in New York, and some of the social security numbers were stored unencrypted. Those affected were only notified on 18 December 2023, more than a year after the incident. Under the Assurance of Discontinuance with the New York Attorney General's office, the company pays 250,000 USD and must introduce, among other things, encryption, password rules, vulnerability testing and an incident response plan. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

Employee data also triggers notification duties – notice must not wait until the data review is fully completed.

Relevance to training and awareness

Multi-factor authentication for all access routes; timely notification of data breaches

Missing or inadequate training played a role in the decision.

Authority / court
Office of the New York State Attorney General (Bureau of Internet & Technology)
Area of law
Data protection · Employee data
Legal basis
New York Executive Law § 63(12); New York General Business Law § 899-aa (Benachrichtigung bei Datenpannen) und § 899-bb (SHIELD Act, Datensicherheit)
Action
Fine
Status of proceedings
final
Sector
Other
Published
15 Nov 2024

Original amount 250,000 USD, converted at the ECB reference rate of 13 Nov 2024.

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8 Nov 2024 Telefónica Venezolana C.A.Telefónica Venezolana: USD 85.26m for bribery in a state currency auction USABribery of public officials €79.1m

The Venezuelan subsidiary of Spain's Telefónica S.A. entered into a DPA and pays a penalty of USD 85,260,000. To be allowed to exchange bolívares for US dollars in a state currency auction in 2014, it had two suppliers pay about USD 28.9 million to an intermediary, part of which went to Venezuelan officials, and covered the cost through overpriced equipment purchases from those suppliers. It received more than USD 110 million from the auction, over 65% of the funds awarded. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

Purchases with conspicuous price mark-ups can fund bribery – pricing anomalies must be part of every compliance review.

Relevance to training and awareness

Inflated purchase prices with suppliers as a hidden channel for bribes

Authority / court
U.S. Department of Justice (Criminal Division, Fraud Section; USAO Southern District of New York)
Area of law
Bribery and corruption · Bribery of public officials
Legal basis
Foreign Corrupt Practices Act (FCPA): Verschwörung zum Verstoß gegen die Anti-Bribery-Vorschriften (Criminal Information, Southern District of New York)
Action
Fine
Status of proceedings
final
Sector
Telecoms, IT and software
Mitigating circumstances
Cooperation (initially diminished by late production of records) and remediation were credited: disciplinary action including dismissals, an independent compliance function with a Chief Compliance Officer, review of all non-standard pricing transactions, tighter third-party controls; 20% reduction.
Published
8 Nov 2024

Original amount 85,260,000 USD, converted at the ECB reference rate of 8 Nov 2024.

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8 Nov 2024 Invesco Advisers, Inc.Invesco Advisers: 17.5 million USD for inflated ESG integration percentages USAMisleading environmental and sustainability claims €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.

What organisations can take from it

Sustainability metrics used in sales need a written definition and a traceable calculation.

Relevance to training and awareness

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.

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

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7 Nov 2024 Aiotec GmbHOFAC: USD 14.55 million settlement with Aiotec over supply of a polypropylene plant to Iran USABreaches of sanctions and embargoes €13.5m

Berlin-based Aiotec GmbH, which sources industrial equipment for the energy sector, is paying USD 14,550,000 under a settlement with OFAC for one apparent violation of the Iran sanctions; USD 9,550,000 of this is suspended as long as Aiotec meets its compliance commitments. Under the settlement agreement, up to a further USD 700,000 may be suspended if spent on sanctions compliance; USD 4.3 million is payable in instalments over seven years. According to OFAC's findings, between 2015 and 2019 the company took part in a conspiracy to cause a US company to sell it a decommissioned Australian polypropylene plant for around USD 9.7 million that was in fact destined for a buyer in Iran; payments of around USD 9.46 million ran through a US bank. OFAC treated the apparent violation as egregious and not voluntarily self-disclosed; the base penalty equalled the statutory maximum of USD 19.4 million. OFAC signed the settlement agreement on 7 November 2024 and published it on 3 December 2024. According to the settlement agreement, the settlement does not constitute an admission by Aiotec of the apparent violation. Source: U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC), enforcement release "Aiotec GmbH Settles with OFAC for $14,550,000 Related to an Apparent Violation of the Iranian Transactions and Sanctions Regulations", 3 December 2024, https://ofac.treasury.gov/media/933661/download?inline; summarised in our own words.

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. § 560.203(b) (Verabredung zur Umgehung; ein mutmaßlicher Verstoß); Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A
Action
Fine
Status of proceedings
final
Sector
Manufacturing and mechanical engineering
Published
3 Dec 2024

Original amount 14,550,000 USD, converted at the ECB reference rate of 7 Nov 2024.

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

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6 Nov 2024 595 Construction LLCIllinois framing contractor: OSHA proposes $287,465 over alleged unprotected work at height USAWorkplace safety and accidents €268,784

According to OSHA, 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. OSHA proposed penalties of $287,465; the violations are alleged and may be contested.

What organisations can take from it

Training records are mandatory, but only daily checks on site prevent falls.

Relevance to training and awareness

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 28 Sep 2026 · Version 3 · Direct link

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1 Nov 2024 GlobalFoundries U.S. Inc.; GlobalFoundries U.S. 2 LLCBIS: USD 500,000 against GlobalFoundries for shipments to a listed company USAExport control and dual-use goods €459,348

As part of a settlement, the Bureau of Industry and Security imposed a civil penalty of USD 500,000 on GlobalFoundries U.S. Inc. and its subsidiary GlobalFoundries U.S. 2 LLC. Between February 2021 and October 2022 the company sent semiconductor wafers worth around USD 17.1 million in 74 shipments without authorisation to SJ Semiconductor, a company on the Entity List; owing to a data entry error, the service provider designated by the customer had not been screened in the screening system. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

Service providers designated by customers, such as test and assembly contractors, must also be screened against sanctions and Entity Lists.

Relevance to training and awareness

Sanctions list screening of all parties to a transaction

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
15 C.F.R. § 764.2(a) (Export Administration Regulations)
Action
Fine
Status of proceedings
final
Sector
Telecoms, IT and software
Mitigating circumstances
According to BIS, voluntary self-disclosure, cooperation and remedial measures led to a significant reduction of the penalty.
Published
1 Nov 2024

Original amount 500,000 USD, converted at the ECB reference rate of 1 Nov 2024.

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

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23 Oct 2024 Goldman Sachs Bank USACFPB: Goldman Sachs Bank USA pays 64.8 million USD over Apple Card failures USAConsumer protection and online retail €41.8m

According to the CFPB, as issuing bank of the Apple Card Goldman failed to acknowledge and resolve transaction disputes on time, reported disputed amounts to credit bureaus prematurely and investigated disputes inadequately (Truth in Lending Act, Regulation Z); the card was launched although the board had been warned shortly beforehand that the dispute system was not fully ready. The bank also gave the misleading impression that device purchases would automatically be converted into interest-free instalments; the order requires 19.8 million USD in redress and a fine of 45 million USD. The authority allegedly made the findings set out here; this account is not based on a final judgment. The amount field records only the civil monetary penalty.

What organisations can take from it

A product must not launch while legally required dispute processes are not working – not even under pressure from a partner.

Relevance to training and awareness

Launching products only after complaint and dispute processes have been signed off

Authority / court
Consumer Financial Protection Bureau (CFPB)
Area of law
Consumer protection and online retail
Legal basis
Truth in Lending Act und Regulation Z; Consumer Financial Protection Act of 2010, §§ 1031, 1036
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Liability of senior managers
The CFPB stresses that the board had been warned four days before the card's launch that the dispute system was not ready.
Published
23 Oct 2024

Original amount 45,000,000 USD, converted at the ECB reference rate of 23 Oct 2024.

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

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23 Oct 2024 Apple Inc.CFPB: Apple pays 25 million USD fine over Apple Card disputes and instalment sales USAMisleading advertising and pricing €23.2m

According to the CFPB, Apple in some cases failed to forward Apple Card users' disputes to the issuing bank Goldman Sachs and designed advertising and the checkout process so that customers wrongly assumed device purchases would automatically be split into interest-free instalments (Apple Card Monthly Installments). The order imposed a fine of 25 million USD; in September 2025 the CFPB terminated it early after the fine had been paid. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

A technology partner that designs customer interfaces for a financial product is itself liable for misleading flows and unhandled disputes.

Relevance to training and awareness

Responsibility of technology partners for customer processes in financial products

Authority / court
Consumer Financial Protection Bureau (CFPB)
Area of law
Consumer protection and online retail · Misleading advertising and pricing
Legal basis
Consumer Financial Protection Act of 2010, §§ 1031, 1036 (12 U.S.C. §§ 5531, 5536) – unlautere, irreführende und missbräuchliche Praktiken
Action
Fine
Status of proceedings
final
Sector
Telecoms, IT and software
Employees
10,000 or more
Published
23 Oct 2024

Original amount 25,000,000 USD, converted at the ECB reference rate of 23 Oct 2024.

Sources

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22 Oct 2024 Unisys Corp.SEC: $4 million against Unisys for downplaying cyber incidents after SolarWinds USADisclosure and reporting obligations €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).

What organisations can take from it

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.

Checked against the official source on 28 Sep 2026 · Version 2 · 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 USASuspicious activity 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.

What organisations can take from it

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.

Relevance to training and awareness

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.

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

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17 Oct 2024 Vietnam Beverage Company LimitedOFAC: USD 860,000 settlement with Vietnam Beverage over beverage sales to North Korea USABreaches of sanctions and embargoes €791,460

Vietnamese holding company Vietnam Beverage Company Limited is paying USD 860,000 under a settlement with OFAC on behalf of two subsidiaries for apparent violations of the North Korea sanctions. According to OFAC's findings, between April 2016 and October 2018 the beverage subsidiaries received payments of around USD 1,141,547 through US financial institutions on 43 occasions for the sale of alcoholic beverages to North Korea, thereby causing those institutions to export financial services to North Korea. OFAC treated the apparent violations as non-egregious and not voluntarily self-disclosed but credited its cooperation and its proactive notification of internal findings; the base penalty was USD 1,720,000. Source: U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC), enforcement release "Vietnam Beverage Company Limited settles with OFAC for $860,000 for Apparent Violations of the North Korea Sanctions Regulations", 17 October 2024, https://ofac.treasury.gov/media/933501/download?inline; summarised in our own words.

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
North Korea Sanctions Regulations, 31 C.F.R. § 510.212 (43 mutmaßliche Verstöße); Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A
Action
Fine
Status of proceedings
final
Sector
Other
Published
17 Oct 2024

Original amount 860,000 USD, converted at the ECB reference rate of 17 Oct 2024.

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

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16 Oct 2024 RTX Corporation (Raytheon Company)RTX (Raytheon) pays around 369 million USD for bribing a Qatari military official USABribery of public officials €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.

What organisations can take from it

Subcontracts without verifiable services are a classic vehicle for bribes – defence exporters must also disclose payment flows to export control authorities.

Relevance to training and awareness

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.

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

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11 Oct 2024 a US aerospace and defence supplierSEC order against a US defence supplier over bribery of Indian public officials by a subsidiary USABribery of public officialsanonymised €1.54m

From 2020 to 2022, employees of the Indian subsidiary of a US aerospace and defence supplier bribed Indian public officials via agents and distributors, among other things to tailor tenders in the group'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.

What organisations can take from it

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.

Relevance to training and awareness

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.

Checked against the official source on 28 Sep 2026 · Version 3 · Company name anonymised since 11 Oct 2026 · Direct link

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10 Oct 2024 a major Canadian bankFederal Reserve: 123.5 million USD against a major Canadian bank over AML oversight failure USAInternal controlsanonymised €113m

The Board of Governors of the Federal Reserve System imposed 123.5 million USD on a major Canadian bank as 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. The bank 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.

What organisations can take from it

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.

Checked against the official source on 28 Sep 2026 · Version 3 · Company name anonymised since 10 Oct 2026 · Direct link

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1 Oct 2024 a US swap trading platformSwap trading platform: 875,000 USD because emergency and security tests were not brought before the board USACritical infrastructureanonymised €789,284

A US 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.

What organisations can take from it

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.

Checked against the official source on 28 Sep 2026 · Version 3 · Company name anonymised since 1 Oct 2026 · Direct link

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30 Sep 2024 a registered swap dealerCFTC: USD 4 million for misreporting more than five million swaps USADisclosure and reporting obligationsanonymised €3.57m

The CFTC fined the registered swap dealer 4 million USD. From 2018 to 2023 the firm reported more than five million swap transactions incorrectly or late, among other things because of a duplicate swap identifier, incorrect primary economic terms and time stamps, and errors in continuation data reporting. The firm admitted the facts; the fine was lower because of substantial cooperation and remediation. The authority allegedly made the findings set out here; this account is not based on a final judgment.

What organisations can take from it

Derivatives reporting chains need ongoing data quality controls; firms that report errors themselves can significantly reduce the sanction.

Authority / court
U.S. Commodity Futures Trading Commission (CFTC)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Sections 2(a)(13) und 4r(a)(3) Commodity Exchange Act; CFTC Regulations 43.3 und 45.3–45.4
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Published
1 Oct 2024

Original amount 4,000,000 USD, converted at the ECB reference rate of 30 Sep 2024.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 30 Sep 2026 · Direct link

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27 Sep 2024 a US landlord of single-family homesLandlord pays 48 million USD in FTC settlement over hidden mandatory fees USAMisleading advertising and pricinganonymised €43m

According to the FTC, the large 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, the landlord is paying 48 million USD for refunds and must include mandatory fees in the advertised price.

What organisations can take from it

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
Employees
1,000 to 9,999
Published
24 Sep 2024

Original amount 48,000,000 USD, converted at the ECB reference rate of 27 Sep 2024.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 27 Sep 2026 · Direct link

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27 Sep 2024 a Singapore-based agricultural supply chain companyAgricultural trader: 3.25 million USD over late reporting of cotton sales USADisclosure and reporting obligationsanonymised €2.91m

The CFTC fined the Singapore-based agricultural supply chain company 3,250,000 USD. In August and September 2021, subsidiaries reported five sales of more than 375,000 bales of US cotton worth over 190 million USD to an Asian buyer to the US Department of Agriculture one to five weeks late, and left them out of seven Form 304 reports to the CFTC. According to the order, this happened knowingly or recklessly, although the company knew that such sales data affects the price of cotton.

What organisations can take from it

Reportable sales must go into regulatory reports straight away, especially large, market-moving transactions.

Relevance to training and awareness

Timely and complete regulatory reporting to authorities

Authority / court
U.S. Commodity Futures Trading Commission (CFTC)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Section 6(c)(1)(A) Commodity Exchange Act (7 U.S.C. § 9(1)(A)); CFTC Regulations 19.02(a) und 180.1(a)(4); frühere CFTC Regulation 19.01(a) (17 C.F.R. § 19.01(a) (2020))
Action
Fine
Status of proceedings
final
Sector
Food and agriculture
Mitigating circumstances
The CFTC recognised the company's cooperation with the investigation and the remediation it described.
Published
27 Sep 2024

Original amount 3,250,000 USD, converted at the ECB reference rate of 27 Sep 2024.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 27 Sep 2026 · Direct link

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26 Sep 2024 a US asset managerSEC: US asset manager pays 500,000 US dollars over NDAs and severance agreement USARetaliation against whistleblowersanonymised €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.

What organisations can take from it

Companies concluding a settlement with a whistleblower may require neither the withdrawal of nor a waiver of reports to authorities.

Relevance to training and awareness

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.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 26 Sep 2026 · Direct link

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16 Sep 2024 a US manufacturer of tuning productsUS tuning manufacturer: 2.914 million USD for over 81,000 tuners that disable emission controls USA, TXEmissions and permitsanonymised €2.62m

Since 2015, the Texas-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.

What organisations can take from it

Tuning products that circumvent emission controls are prohibited even as ‘racing parts’ – product approvals require an emissions review.

Relevance to training and awareness

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.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 16 Sep 2026 · Direct link

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16 Sep 2024 five Californian outlet companies of a fast-food franchiseeFast-food franchisee: 1.7 million USD – overtime evaded by splitting up companies USA, CAWorking timeanonymised €1.53m

The franchisee ran five outlets of a fast-food chain in California 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.

What organisations can take from it

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
Measures against individuals are not reported here.

Original amount 1,700,000 USD, converted at the ECB reference rate of 16 Sep 2024.

Checked against the official source on 28 Sep 2026 · Version 6 · Company name anonymised since 16 Sep 2026 · Direct link

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10 Sep 2024 a US agricultural machinery groupMachinery group pays 9.9 million USD: Thai subsidiary bribed air force and highways authority USAGifts, hospitality and benefitsanonymised €9m

From 2017 to 2020, the acquired Thai subsidiary 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. The group is paying 4,343,401 USD in disgorgement, 1,086,954 USD in interest and a penalty of 4.5 million USD.

What organisations can take from it

After acquisitions, integrate subsidiaries swiftly into the compliance programme and controls – otherwise old practices such as luxury trips for customers live on.

Relevance to training and awareness

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
Published
10 Sep 2024

Original amount 9,930,355 USD, converted at the ECB reference rate of 10 Sep 2024.

Checked against the official source on 28 Sep 2026 · Version 5 · Company name anonymised since 10 Sep 2026 · Direct link

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10 Sep 2024 a US beverage groupBeverage group: inaccurate recyclability statements on coffee pods in the annual report USADisclosure and reporting obligationsanonymised €1.36m

In its 2019 and 2020 annual reports, the group claimed that tests confirmed the recyclability of its coffee pods, but failed to disclose that two of the largest US recycling companies had expressed significant concerns and stated that they did not currently intend to accept the pods. The group is paying a civil penalty of 1.5 million USD.

What organisations can take from it

Sustainability statements in mandatory reports must be complete – known objections from customers are part of this.

Authority / court
U.S. Securities and Exchange Commission (SEC)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Section 13(a) Securities Exchange Act 1934, Rule 13a-1
Action
Fine
Status of proceedings
final
Sector
Food and agriculture

Original amount 1,500,000 USD, converted at the ECB reference rate of 10 Sep 2024.

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

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10 Sep 2024 a US manufacturer of vehicle tuning partsUS tuning parts manufacturer: criminal fine and civil settlement over defeat devices USAEmissions and permitsanonymised Fine

According to the EPA, a US manufacturer of vehicle tuning parts manufactured, sold or installed large numbers of parts for diesel pickups over several years that could remove or disable emission control systems; according to the EPA, the additional emissions equalled those of several million additional vehicles. In the criminal proceedings, the company received a multi-million-dollar fine and a term of probation; a civil settlement providing for a multi-million-dollar civil penalty payable in instalments was subject to court approval.

What organisations can take from it

Running emissions tampering as a business model leads to criminal and civil sanctions against the company.

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.

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9 Sep 2024 a US healthcare companySEC: healthcare company pays 1,386,000 USD over waivers of whistleblower awards USARetaliation against whistleblowersanonymised €1.26m

Between July 2019 and July 2023, the healthcare company had employees waive potential awards for reports to authorities in 98 employment, separation, retention and settlement agreements; in 56 further separation and settlement agreements, they had to waive complaints to federal authorities. As part of a sweep against seven listed companies, the company paid 1,386,000 US dollars to the U.S. Securities and Exchange Commission (SEC); the contract templates were amended.

What organisations can take from it

Separation and employment agreements must restrict neither reports to authorities nor the entitlement to whistleblower awards.

Relevance to training and awareness

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
Healthcare
Mitigating circumstances
Partial amendment of the templates even before contact by the SEC, information provided to those affected, and cooperation
Published
9 Sep 2024

Original amount 1,386,000 USD, converted at the ECB reference rate of 9 Sep 2024.

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9 Sep 2024 a US software providerSEC: US software provider pays 692,250 US dollars over waivers of whistleblower awards USARetaliation against whistleblowersanonymised €626,868

The provider of property management software had employees waive potential awards for reports to authorities in two employment agreements and one settlement agreement; 68 consulting agreements (January 2020 to October 2023) prohibited voluntary disclosures to authorities. As part of a sweep against seven listed companies, the provider paid 692,250 US dollars to the U.S. Securities and Exchange Commission (SEC); the contract templates were amended.

What organisations can take from it

Separation and employment agreements must restrict neither reports to authorities nor the entitlement to whistleblower awards.

Relevance to training and awareness

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
Telecoms, IT and software
Employees
1,000 to 9,999
Mitigating circumstances
Amendment of the templates after contact by the SEC, information provided to those affected, and cooperation
Published
9 Sep 2024

Original amount 692,250 USD, converted at the ECB reference rate of 9 Sep 2024.

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9 Sep 2024 a US financial services companySEC: US financial services company pays 312,000 US dollars over waivers of whistleblower awards USARetaliation against whistleblowersanonymised €282,532

Between May 2019 and September 2023, the company had senior employees waive potential awards for reports to authorities in 29 severance, separation and incentive agreements; three consulting agreements prohibited voluntary disclosures to authorities. As part of a sweep against seven listed companies, the company paid 312,000 US dollars to the U.S. Securities and Exchange Commission (SEC); the contract templates were amended.

What organisations can take from it

Separation and employment agreements must restrict neither reports to authorities nor the entitlement to whistleblower awards.

Relevance to training and awareness

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
Financial services and insurance
Mitigating circumstances
Amendment of the templates after contact by the SEC, information provided to those affected, and cooperation
Published
9 Sep 2024

Original amount 312,000 USD, converted at the ECB reference rate of 9 Sep 2024.

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9 Sep 2024 a small US manufacturer of nutrition productsSEC: US nutrition products manufacturer pays 19,500 US dollars over waivers of whistleblower awards USARetaliation against whistleblowersanonymised €17,658

The manufacturer of nutrition and wellness products had two departing employees waive potential awards for reports to authorities in separation agreements (May 2022 and June 2023). As part of a sweep against seven listed companies, the manufacturer paid 19,500 US dollars; the U.S. Securities and Exchange Commission (SEC) also took into account the company's strained financial situation.

What organisations can take from it

Separation and employment agreements must restrict neither reports to authorities nor the entitlement to whistleblower awards.

Relevance to training and awareness

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
Food and agriculture
Employees
Under 50
Mitigating circumstances
Amendment of the templates and information provided to those affected after contact by the SEC, cooperation and strained financial situation
Published
9 Sep 2024

Original amount 19,500 USD, converted at the ECB reference rate of 9 Sep 2024.

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4 Sep 2024 three US financial advisory firmsSEC: Three US financial advisory firms pay 240,000 US dollars over reporting prohibitions USARetaliation against whistleblowersanonymised €217,195

From May 2021 to February 2024, the three New Jersey firms had eleven retail clients sign confidentiality agreements in connection with settlement payments that permitted reports to the SEC only at the SEC's initiative; in some cases, clients had to confirm that they had never contacted and would never contact authorities. Penalties imposed by the U.S. Securities and Exchange Commission (SEC): 160,000 (the asset management company), 70,000 (the financial planning company) and 10,000 US dollars (the third firm, a wealth manager).

What organisations can take from it

Complaint settlements with clients must not require an assurance not to contact authorities.

Relevance to training and awareness

Whistleblower protection in complaint and settlement processes

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
Financial services and insurance
Published
4 Sep 2024

Original amount 240,000 USD, converted at the ECB reference rate of 4 Sep 2024.

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29 Aug 2024 a US defence groupDDTC: USD 200 million against US defence group for ITAR violations USAExport control and dual-use goodsanonymised €180.4m

The US State Department's Directorate of Defense Trade Controls settled with a US defence group for a civil penalty of USD 200 million for violations of the Arms Export Control Act and the ITAR. The allegations concerned unauthorised exports of defence articles resulting from flawed jurisdiction and classification decisions, further unauthorised exports, including of classified defence articles, hand-carried exports by employees to countries proscribed under ITAR § 126.1, and breaches of authorisation provisos. USD 100 million is suspended provided the group spends it on approved compliance measures; USD 100 million is payable in three instalments.

What organisations can take from it

Correct jurisdiction and classification decisions are the basis of every export authorisation; errors there multiply across the portfolio.

Relevance to training and awareness

Export control for defence articles: classification, hand-carry and authorisation provisos

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
Employees
10,000 or more
Mitigating circumstances
The allegations are based on facts that the group itself disclosed to the DDTC.

Original amount 200,000,000 USD, converted at the ECB reference rate of 29 Aug 2024.

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28 Aug 2024 a former US futures exchangeFormer futures exchange: 22 million USD over hidden volume incentives and false statements USADisclosure and reporting obligationsanonymised €19.8m

The CFTC fined the former designated contract market 22 million USD. Between 2015 and 2018, the exchange made volume-based payments to certain participants in its market maker programme on top of the disclosed fixed stipend, did not disclose this to the CFTC, the public, its own compliance staff or its regulatory service provider, and made false and misleading statements to the CFTC about it. It also failed to follow its regulatory service provider's recommendation concerning certain trading activity and did not record why.

What organisations can take from it

A trading venue's incentive programmes must be fully disclosed and known to its own compliance function; inaccurate information given to the supervisor is a separate breach.

Relevance to training and awareness

Truthful and complete statements to supervisory authorities

Authority / court
U.S. Commodity Futures Trading Commission (CFTC)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Sections 5(d)(2), 5(d)(7), 5(d)(12) und 6(c)(2) Commodity Exchange Act; CFTC Regulations 38.150, 38.154(c), 38.400, 38.401(b), 38.650, 38.651, 38.4(b) und 40.6
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
29 Aug 2024

Original amount 22,000,000 USD, converted at the ECB reference rate of 28 Aug 2024.

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27 Aug 2024 the trading subsidiary of a European energy groupEnergy group's trading subsidiary: attempted manipulation of gasoline futures USAMarket abuse and insider dealinganonymised €43m

The trading company sold physical gasoline below the bids in order to depress the benchmark price and thereby benefit its short positions in EBOB-related futures. Under the settlement, it is paying a civil penalty of 48 million USD.

What organisations can take from it

Monitor physical trading and derivatives positions together, because manipulation often takes place via the benchmark price.

Relevance to training and awareness

Market manipulation in commodities trading (physical transactions to benefit derivatives positions)

Authority / court
U.S. Commodity Futures Trading Commission (CFTC)
Area of law
Capital markets and financial supervision · Market abuse and insider dealing
Legal basis
Commodity Exchange Act und CFTC-Regulations (versuchte Marktmanipulation)
Action
Fine
Status of proceedings
final
Sector
Energy and utilities

Original amount 48,000,000 USD, converted at the ECB reference rate of 27 Aug 2024.

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27 Aug 2024 a European major bankNYDFS: USD 35 million against a European major bank for AML failures in foreign branches USA, New YorkCustomer due diligenceanonymised €31.4m

The NYDFS imposed a penalty of allegedly USD 35 million on a European major bank and its branch in New York. The bank had not maintained an effective AML programme in several foreign branches, had not adequately reviewed correspondent banking and RMA relationships and had not operated adequate transaction monitoring; it also helped customers set up hundreds of offshore accounts.

What organisations can take from it

AML weaknesses in individual foreign units reflect on the whole group and must be managed group-wide.

Relevance to training and awareness

Group-wide anti-money laundering and due diligence in correspondent banking

Authority / court
New York State Department of Financial Services (NYDFS)
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
3 N.Y.C.R.R. § 116.2; 3 N.Y.C.R.R. § 504.3 (so zitiert); New York Banking Law §§ 39, 44
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Mitigating circumstances
The NYDFS gave substantial weight to the bank's extensive cooperation during the investigation and its remediation efforts, including substantial investment in compliance resources.
Published
27 Aug 2024

Original amount 35,000,000 USD, converted at the ECB reference rate of 27 Aug 2024.

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27 Aug 2024 a US steelworksSteelworks: EPA settlement over pollutant emissions USAEmissions and permitsanonymised €222,537

The steelworks on Lake Michigan allegedly emitted excessive particulate matter and hazardous air pollutants when charging the basic oxygen furnaces and during overflows of molten material. Under the settlement with the U.S. Environmental Protection Agency (EPA), the company is paying 248,396 USD and must charge more slowly, improve extraction and monitoring, and introduce video recording and reporting to the EPA.

What organisations can take from it

Emission peaks often result from operating procedures; binding work instructions and documentation are part of permit compliance.

Relevance to training and awareness

Operating procedures for reducing emissions in production

Authority / court
U.S. Environmental Protection Agency (EPA)
Area of law
Environment and sustainability · Emissions and permits
Legal basis
Clean Air Act
Action
Fine
Status of proceedings
final
Sector
Steel and metals
Published
27 Aug 2024

Original amount 248,396 USD, converted at the ECB reference rate of 27 Aug 2024.

Sources

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21 Aug 2024 a US provider of generative AI for hospitalsTexas obliges AI provider for hospitals to give honest accuracy claims USA, TXAI systemsanonymised Order

The Texas Attorney General's office concluded an Assurance of Voluntary Compliance with a Texas-based provider of generative AI for hospitals and submitted it to the court for approval. The provider had advertised the accuracy of its software, which summarises patient data for hospital staff, including with a 'severe hallucination' rate of less than 1 in 100,000; the authority considered these metrics likely to be inaccurate and misleading. For five years the provider must clearly explain such metrics in its advertising or have them substantiated by an independent auditor, and must disclose to its customers the risks, limitations and appropriate use of its products; the company denies any wrongdoing, and no payment is provided for.

What organisations can take from it

Reliability metrics for AI need a disclosed definition and measurement method – and users must know when they should not rely on the system.

Relevance to training and awareness

Performance claims for AI systems; limitations and appropriate use of AI in clinical practice

Authority / court
Office of the Attorney General of Texas, Consumer Protection Division
Area of law
AI and digital regulation · AI systems
Legal basis
Texas Deceptive Trade Practices–Consumer Protection Act (DTPA), Tex. Bus. & Com. Code §§ 17.41–17.63; Zusicherung nach § 17.58
Action
Order
Status of proceedings
unknown
Sector
Healthcare
Published
18 Sep 2024

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19 Aug 2024 two companies of a Brazilian sugar and energy groupSugar group: 750,000 USD over intra-group wash sales in sugar futures USAMarket abuse and insider dealinganonymised €679,286

The CFTC imposed a fine of 750,000 USD, jointly and severally, on a Brazilian and a Swiss company of a Brazilian sugar and energy group. From March to September 2022, the two group companies executed 44 exchange for physical transactions in sugar futures on a US futures exchange between accounts that were not independently controlled, in order to transfer physical sugar within the group; the CFTC treated them as prohibited wash sales and non-competitive transactions. More than 50,000 contracts worth over 1 billion USD were involved; the companies admitted the facts.

What organisations can take from it

Intra-group transfers through the exchange are wash sales if both sides are not independently controlled; other routes are needed for them.

Relevance to training and awareness

Wash sales and intra-group exchange transactions

Missing or inadequate training played a role in the decision.

Authority / court
U.S. Commodity Futures Trading Commission (CFTC)
Area of law
Capital markets and financial supervision · Market abuse and insider dealing
Legal basis
Section 4c(a)(1) und (2)(A) Commodity Exchange Act (7 U.S.C. § 6c(a)(1), (2)(A)); CFTC Regulation 1.38(a)
Action
Fine
Status of proceedings
final
Sector
Food and agriculture
Mitigating circumstances
The CFTC acknowledged the remediation described: stopping intra-group EFPs, a written compliance manual, training on US law, annual training programmes and additional compliance staff.
Published
19 Aug 2024

Original amount 750,000 USD, converted at the ECB reference rate of 19 Aug 2024.

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9 Aug 2024 a Hong Kong magnesium producerUFLPA list: Hong Kong magnesium producer added USAForced and child labouranonymised Other

The Forced Labor Enforcement Task Force chaired by the US Department of Homeland Security added a Hong Kong-based manufacturer of magnesium fertiliser and magnesium alloys to the UFLPA Entity List because the US government has reasonable cause to believe that it sources magnesium from the Xinjiang region. Its goods are therefore subject to the rebuttable presumption that they were made with forced labour and may not be imported into the United States.

What organisations can take from it

Raw materials must be traced back to their region of origin – even indirect links to Xinjiang can block imports into the United States.

Relevance to training and awareness

Origin of raw materials and forced labour risks in the supply chain

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, Sec. 2(d)(2)(B)(v) und Sec. 3(a); 19 U.S.C. 1307
Action
Other
Status of proceedings
unknown
Sector
Steel and metals
Published
9 Aug 2024

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9 Aug 2024 a Chinese mining companyUFLPA list: Chinese mining company added USAForced and child labouranonymised Other

The Forced Labor Enforcement Task Force chaired by the US Department of Homeland Security added a Xinjiang-based mining company (non-ferrous metals) to the UFLPA Entity List because the US government has reasonable cause to believe that it works with the Xinjiang regional government to recruit, transport and receive Uyghurs, Kazakhs, Kyrgyz and members of other persecuted groups. Its goods are therefore presumed to have been made with forced labour and are barred from import into the United States unless the presumption is rebutted.

What organisations can take from it

For metals from China, screening against the UFLPA Entity List down to mine level belongs in every supplier assessment.

Relevance to training and awareness

Forced labour risks in metals and raw materials

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, Sec. 2(d)(2)(B)(ii) und Sec. 3(a); 19 U.S.C. 1307
Action
Other
Status of proceedings
unknown
Sector
Steel and metals
Published
9 Aug 2024

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18 Jul 2024 a major US dialysis groupUS dialysis group: 34.5 million USD – kickbacks for referrals to dialysis centres and pharmacy USACommercial briberyanonymised €31.6m

The dialysis group allegedly paid kickbacks to promote referrals to its former pharmacy subsidiary and granted benefits to nephrologists and vascular surgeons to induce them to send patients to the group's dialysis centres. The group paid 34,487,390 USD.

What organisations can take from it

Intra-group routing of customers to subsidiaries must not be bought with benefits for third parties.

Relevance to training and awareness

Benefits for 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
Employees
10,000 or more

Original amount 34,487,390 USD, converted at the ECB reference rate of 18 Jul 2024.

Sources

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1 Jul 2024 three US home health agencies and their parent companyUS home health group: 4.5 million USD – kickbacks to senior living facilities and physicians USACommercial briberyanonymised €4.18m

Three home health agencies in Texas, Ohio and Indiana and their parent company allegedly granted kickbacks to assisted living facilities and physicians for Medicare referrals. They paid 4,496,330 USD.

What organisations can take from it

Cooperation with facilities that refer customers requires written contracts with remuneration at market rates and regular review.

Relevance to training and awareness

Benefits for cooperation partners who refer customers

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

Original amount 4,496,330 USD, converted at the ECB reference rate of 1 Jul 2024.

Sources

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26 Jun 2024 a British software maker and two subsidiariesSoftware maker: 16.5 million USD and ban on selling browsing data USACookies and trackinganonymised €15.4m

The FTC issued its final order against a British software maker, its Czech subsidiary and its former data subsidiary. According to the authority, the software maker collected detailed browsing data through browser extensions and antivirus software, stored it indefinitely and sold it via the data subsidiary to more than 100 third parties without adequate notice and consent, even though the products were marketed as protecting against online tracking. The software maker must pay 16,500,000 USD for consumer redress, may no longer sell or license browsing data for advertising purposes, must delete the data transferred to the data subsidiary together with any products and algorithms derived from it, and must set up a privacy programme.

What organisations can take from it

A company that advertises protection against tracking must not monetise the same usage data itself – marketing claims and data use must match.

Relevance to training and awareness

Privacy promises versus actual data use; sale of usage data

Authority / court
Federal Trade Commission (FTC)
Area of law
Data protection · Cookies and tracking
Legal basis
Section 5(a) FTC Act, 15 U.S.C. § 45(a) (unlautere und irreführende Praktiken)
Action
Disgorgement of profits
Status of proceedings
final
Sector
Telecoms, IT and software
Published
27 Jun 2024

Original amount 16,500,000 USD, converted at the ECB reference rate of 26 Jun 2024.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 26 Jun 2026 · Direct link

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26 Jun 2024 an Italian animation companyOFAC: USD 538,000 settlement with Italian animation company over payments to a North Korean animation studio USABreaches of sanctions and embargoesanonymised €503,321

A Rome-based animation company is paying USD 538,000 under a settlement with OFAC for apparent violations of the North Korea sanctions. According to OFAC's findings, between May 2019 and November 2021 the company remitted around USD 537,939 to a North Korean state-owned animation studio for outsourced animation work. As a result, US financial institutions processed wire transfers in which the Government of North Korea had a blocked interest and exported financial services to North Korea. OFAC treated the apparent violations as non-egregious and not voluntarily self-disclosed; the base penalty was USD 725,000. Summarised in our own words.

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
North Korea Sanctions Regulations, 31 C.F.R. § 510.212; Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A
Action
Fine
Status of proceedings
final
Sector
Media and online platforms
Published
26 Jun 2024

Original amount 538,000 USD, converted at the ECB reference rate of 26 Jun 2024.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 26 Jun 2026 · Direct link

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18 Jun 2024 a major US online retailerUS online retailer: 5.9 million USD – undisclosed productivity quotas in two warehouses (Warehouse Quotas Law) USA, CAWorking timeanonymised €5.51m

The online retailer did not inform employees at two warehouses in Southern California in writing of the productivity quotas that applied; the authority regarded the peer-to-peer rating system used as a quota within the meaning of the law, which prohibits quotas that prevent breaks, toilet visits or compliance with health and safety. For 59,017 violations between October 2023 and March 2024, the Labor Commissioner’s Office imposed 5,901,700 USD.

What organisations can take from it

Disclose performance metrics for employees, and do not let them effectively prevent breaks – even when they come in the guise of peer ratings.

Relevance to training and awareness

Making productivity quotas and break rights transparent (managers)

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 Warehouse Quotas Law (AB 701, Labor Code §§ 2100 ff.); Labor Code § 2699(f)
Action
Fine
Status of proceedings
unknown
Sector
Retail and e-commerce
Employees
10,000 or more

Original amount 5,901,700 USD, converted at the ECB reference rate of 18 Jun 2024.

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

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17 Jun 2024 a US trading company of an international commodity trading groupCommodity trader: 55 million USD for third-party inside information, benchmark manipulation, gagging NDAs USAMarket abuse and insider dealinganonymised €51.3m

From 2014 to April 2019 the US trading company of an international commodity trading group traded gasoline while in possession of confidential information that an employee of a Mexican trading entity had passed on in breach of his duties, and in February 2017 it artificially pushed up the USGC HSFO benchmark by buying 80 cargoes of fuel oil (3.6 million barrels) in the Platts trading window to benefit its own derivatives positions. In addition, broadly drafted confidentiality clauses in employment and separation agreements (2017–2020) hindered employees from contacting the CFTC (U.S. Commodity Futures Trading Commission) directly – according to the regulator, its first action of this kind against a company. Under a settlement, the trader pays a civil monetary penalty of 55,000,000 USD and must amend the clauses.

What organisations can take from it

Confidentiality clauses need an express carve-out for reports to the authorities, and market information from other firms must be checked for its origin before trading on it.

Relevance to training and awareness

Handling third parties' confidential information in commodity trading; not blocking reporting channels to authorities by contract

Authority / court
U.S. Commodity Futures Trading Commission (CFTC)
Area of law
Capital markets and financial supervision · Market abuse and insider dealing
Legal basis
Section 6(c)(1) und Section 23(h)–(j) Commodity Exchange Act; CFTC Regulations 180.1(a)(1), (3) und 165.19
Action
Fine
Status of proceedings
final
Sector
Energy and utilities
Mitigating circumstances
According to the trader, it voluntarily took remedial action (market integrity policies, controls on market-related communications, more training and compliance testing).
Published
17 Jun 2024

Original amount 55,000,000 USD, converted at the ECB reference rate of 17 Jun 2024.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 17 Jun 2026 · Direct link

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12 Jun 2024 a Californian care facilityCalifornian care facility: 658,948 USD – care workers up to 24 hours without breaks USA, CAWorking timeanonymised €612,121

At the care facility, employees worked up to 24 hours a day, seven days a week, were not allowed to leave the premises, had to work through breaks and received no overtime pay. The settlement of 658,948 USD comprises 608,948 USD for 34 employees (including overtime and break premiums) and 50,000 USD in civil penalties.

What organisations can take from it

Round-the-clock shifts without rest periods are a recurring pattern in care – rosters need checks against maximum working hours and breaks.

Relevance to training and awareness

Working time limits and breaks in care

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 (Überstunden, Meal and Rest Periods, Mindestlohn)
Action
Other
Status of proceedings
final
Sector
Healthcare

Original amount 658,948 USD, converted at the ECB reference rate of 12 Jun 2024.

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

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7 Jun 2024 a US custody bankOFAC: USD 7.45m settlement with US custody bank over invoices from a software subsidiary to Russian customers USABreaches of sanctions and embargoesanonymised €6.84m

A Massachusetts custody bank is paying USD 7,452,501 under a settlement with OFAC on behalf of itself and its software subsidiary for 38 apparent violations of the Ukraine-/Russia-related sanctions. According to OFAC's findings, between 2016 and 2020 the software subsidiary repeatedly redated or reissued invoices worth around USD 1.27 million to customers subject to Directive 1 under Executive Order 13662 and accepted payments after the permitted debt tenors had expired, which amounted to prohibited new debt. OFAC treated the apparent violations as egregious and not voluntarily self-disclosed and took cooperation and remediation into account; the base penalty equalled the statutory maximum of USD 13,550,002. OFAC signed the settlement agreement on 7 June 2024 and published it on 26 July 2024. Summarised in our own words.

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. § 589.202 i. V. m. Directive 1 zu E.O. 13662 (38 mutmaßliche Verstöße); Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
26 Jul 2024

Original amount 7,452,501 USD, converted at the ECB reference rate of 7 Jun 2024.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 7 Jun 2026 · Direct link

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29 May 2024 a US manufacturer of spinal implantsUS implant manufacturer: 12 million USD – kickbacks to spine surgeons USACommercial briberyanonymised €11.1m

The Utah manufacturer of spinal implants allegedly paid surgeons kickbacks to induce them to use the manufacturer's products. The settlement of 12 million USD is a joint payment by the company and other settling parties; HHS-OIG placed the company under heightened scrutiny.

What organisations can take from it

Consultancy agreements, royalty payments or fees to users who decide on the use of products require proof of need and a fair market value review.

Relevance to training and awareness

Payments to users of medical devices

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
Measures against individuals are not reported here.

Original amount 12,000,000 USD, converted at the ECB reference rate of 29 May 2024.

Sources

Checked against the official source on 28 Sep 2026 · Version 6 · Company name anonymised since 29 May 2026 · Direct link

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23 May 2024 a US futures commission merchant and swap dealerFutures commission merchant: 200 million USD over gaps in trade surveillance USAOrganisational requirementsanonymised €184.3m

The CFTC fined the futures commission merchant and swap dealer 200 million USD for failing to supervise its business diligently. Because data feeds were misconfigured and data delivered directly by exchanges was not reconciled for completeness, billions of order messages on a US designated contract market went unsurveilled from 2014 to 2021. 50 million USD each from the March 2024 resolutions with the Office of the Comptroller of the Currency and the Federal Reserve Board is credited against the fine.

What organisations can take from it

Even data received directly from exchanges must be checked regularly for completeness before trade surveillance relies on it.

Authority / court
U.S. Commodity Futures Trading Commission (CFTC)
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
CFTC Regulation 166.3 (17 C.F.R. § 166.3)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
The firm admitted the findings on the scope and causes of the surveillance gaps, has by its own account put a remediation programme in place and closed the gaps by 2023.
Published
23 May 2024

Original amount 200,000,000 USD, converted at the ECB reference rate of 23 May 2024.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 23 May 2026 · Direct link

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22 May 2024 a US exchange group and nine of its subsidiariesUS exchange group: 10 million USD – cyber attack not reported to the SEC USAIncident reporting obligationsanonymised €9.23m

In April 2021, a third party alerted the group to a vulnerability in its VPN; the group found malicious code that had been inserted but did not inform the legal and compliance officers of its exchange and clearing subsidiaries for days. As a result, the subsidiaries, including a stock exchange, did not immediately report the incident to the U.S. Securities and Exchange Commission (SEC) as required under Regulation SCI; the group paid 10 million USD.

What organisations can take from it

Operators of critical market infrastructure need internal reporting channels that pass cyber incidents on to all entities subject to reporting obligations within hours.

Relevance to training and awareness

Internal escalation of cyber incidents to compliance

Authority / court
U.S. Securities and Exchange Commission (SEC)
Area of law
Information security and cyber · Incident reporting obligations
Legal basis
Regulation Systems Compliance and Integrity (Regulation SCI), Meldepflichten
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Repeat case
yes

Original amount 10,000,000 USD, converted at the ECB reference rate of 22 May 2024.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 22 May 2026 · Direct link

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20 May 2024 a US data services providerFTC: US data services provider must delete legacy data and strengthen security after hacker attack USASecurity measures and risk managementanonymised Order

According to the complaint of the Federal Trade Commission (FTC, the US consumer protection authority), an attacker exploited weaknesses in the network of the data services provider for companies and non-profit organisations in early 2020 and stole large amounts of unencrypted data, including Social Security and bank account numbers of millions of people; the attack went undetected for three months, the provider informed its customers only after almost two months and misrepresented the extent. The final order requires a comprehensive security programme, a data retention schedule, deletion of data no longer needed and notification of future reportable incidents to the FTC.

What organisations can take from it

Set retention periods and deletion routines as security measures – data that is no longer needed is pure risk in an attack.

Relevance to training and awareness

Data minimisation, encryption and honest incident communication

Authority / court
Federal Trade Commission (FTC)
Area of law
Information security and cyber · Security measures and risk management
Legal basis
Section 5 FTC Act
Action
Order
Status of proceedings
final
Sector
Telecoms, IT and software
Published
20 May 2024

Checked against the official source on 28 Sep 2026 · Version 3 · Company name anonymised since 20 May 2026 · Direct link

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25 Apr 2024 a US kitchenware and home furnishings retailerRetailer pays 3.18 million USD penalty over false "Made in USA" claims USAMisleading advertising and pricinganonymised €2.96m

According to the FTC, a kitchenware and home furnishings retailer offered several products as "Made in USA" that were in fact made in China and other countries, thereby breaching a 2020 FTC order on origin claims. On a complaint by the Department of Justice, the federal court entered an agreed order with a civil penalty of 3,175,387 USD, the highest to date in a "Made in USA" case, and annual compliance certifications for five years.

What organisations can take from it

A company already under an order needs sign-off for every origin claim in its range, otherwise a civil penalty follows.

Relevance to training and awareness

Origin claims in product copy and online shops

Authority / court
Federal Trade Commission (FTC); Klage durch das U.S. Department of Justice
Area of law
Consumer protection and online retail · Misleading advertising and pricing
Legal basis
Section 5(l) FTC Act (15 U.S.C. § 45(l)) – Verstoß gegen die FTC Decision and Order von 2020
Action
Fine
Status of proceedings
final
Sector
Retail and e-commerce
Repeat case
yes
Published
26 Apr 2024

Original amount 3,175,387 USD, converted at the ECB reference rate of 25 Apr 2024.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 25 Apr 2026 · Direct link

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19 Apr 2024 a Thai plastics companyThai plastics company pays 20 million USD for concealed sales of Iranian polyethylene USABreaches of sanctions and embargoesanonymised €18.8m

In 2017–2018, the Thai plastics company had US banks process 467 payments totalling 291 million USD for HDPE plastic produced in an Iranian joint venture with the Iranian state-owned petrochemical group. Shipping and documentation practices concealed the Iranian origin. The penalty was imposed by the US Treasury's Office of Foreign Assets Control (OFAC).

What organisations can take from it

Invoicing in US dollars brings US sanctions law into the business – holdings in embargoed countries require strict separation of payment flows.

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)
Action
Fine
Status of proceedings
final
Sector
Chemicals and pharmaceuticals
Culpability
intentional
Published
19 Apr 2024

Original amount 20,000,000 USD, converted at the ECB reference rate of 19 Apr 2024.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 19 Apr 2026 · Direct link

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18 Mar 2024 a US investment adviserSEC ‘AI washing’: investment adviser pays 225,000 US dollars for fabricated AI use USAAI systemsanonymised €206,574

From 2019 to 2023, the investment adviser claimed to use AI and machine learning to analyse client data for investment decisions but did not have these capabilities. In a settlement with the U.S. Securities and Exchange Commission (SEC) (without admission), the adviser paid 225,000 US dollars.

What organisations can take from it

Statements about the use of AI in marketing and investor information must be technically verifiable.

Relevance to training and awareness

Permissible advertising claims about AI capabilities

Authority / court
U.S. Securities and Exchange Commission
Area of law
AI and digital regulation · AI systems
Legal basis
Investment Advisers Act of 1940; Marketing Rule
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
18 Mar 2024

Original amount 225,000 USD, converted at the ECB reference rate of 18 Mar 2024.

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

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18 Mar 2024 a US investment adviserSEC ‘AI washing’: investment adviser pays 175,000 US dollars for AI advertising promises USAAI systemsanonymised €160,668

In 2023, the investment adviser falsely advertised itself as the ‘first regulated AI financial advisor’ offering AI-driven expert forecasts, misrepresented tax-loss harvesting and used impermissible liability clauses. In a settlement with the U.S. Securities and Exchange Commission (SEC), the company paid 175,000 US dollars.

What organisations can take from it

Superlatives such as ‘first AI adviser’ are statements of fact and must be checked before publication.

Relevance to training and awareness

Permissible advertising claims about AI capabilities

Authority / court
U.S. Securities and Exchange Commission
Area of law
AI and digital regulation · AI systems
Legal basis
Investment Advisers Act of 1940; Marketing Rule
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
18 Mar 2024

Original amount 175,000 USD, converted at the ECB reference rate of 18 Mar 2024.

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

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14 Mar 2024 a Swiss private banking groupOFAC: USD 3.74 million settlement with Swiss private banking group over securities transactions for customers in Cuba and blocked persons USABreaches of sanctions and embargoesanonymised €3.42m

A Swiss private banking group is paying USD 3,740,442 under a settlement with OFAC for apparent violations of multiple sanctions programmes; USD 1,000,000 of this is suspended pending completion of certain compliance commitments. According to OFAC's findings, between 2014 and 2018 entities of the group caused US securities firms to process 727 securities transactions worth USD 29,939,701 for customers in Cuba and 141 transactions worth USD 468,615 for a person blocked under the Kingpin Act; in 2023 five dividend payments to a person blocked under the Russia sanctions followed. In total 873 transactions worth USD 30,409,488 were involved. OFAC treated the apparent violations as voluntarily self-disclosed and non-egregious; the base penalty was USD 10,686,977. Summarised in our own words.

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. § 515.201; Foreign Narcotics Kingpin Sanctions Regulations, 31 C.F.R. § 598.202; Russian Harmful Foreign Activities Sanctions Regulations, 31 C.F.R. § 587.201; Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
14 Mar 2024

Original amount 3,740,442 USD, converted at the ECB reference rate of 14 Mar 2024.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 14 Mar 2026 · Direct link

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4 Mar 2024 a Japanese engine manufacturerJapanese engine manufacturer: USD 16.2m CARB settlement over refrigeration unit engines USA, CaliforniaEmissions and permitsanonymised €14.9m

The California Air Resources Board (CARB) reached a settlement of 16,196,120 USD with a Japanese engine manufacturer. Almost 20,000 engines, mainly for transport refrigeration units, were affected: an incompletely reported auxiliary emission control device (AECD), the use of test procedures not applicable to the engine type, and the production of large spark-ignition engines not covered by the CARB certification. According to CARB, the company made modifications to address the incomplete reporting so that it will meet certification requirements in future.

What organisations can take from it

Every device that affects emission control belongs in full in the certification application – even for small engines.

Relevance to training and awareness

Complete information in certification procedures

Authority / court
California Air Resources Board (CARB)
Area of law
Environment and sustainability · Emissions and permits
Legal basis
CARB Off-Road Compression-Ignition Engines and Equipment Regulation
Action
Fine
Status of proceedings
final
Sector
Manufacturing and mechanical engineering
Published
4 Mar 2024

Original amount 16,196,120 USD, converted at the ECB reference rate of 4 Mar 2024.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 4 Mar 2026 · Direct link

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28 Feb 2024 a US aerospace groupDDTC: USD 51 million against US aerospace group for unauthorised technical data transfers USAExport control and dual-use goodsanonymised €47.2m

The DDTC settled with a US aerospace group for a civil penalty of USD 51 million for ITAR violations: unauthorised exports and retransfers of technical data to foreign-person employees and contractors, unauthorised exports to the People's Republic of China as a proscribed country, and breaches of authorisation provisos. USD 24 million is suspended for approved compliance measures; USD 27 million is payable in three instalments.

What organisations can take from it

Access by foreign-person employees to controlled technical data is an export and requires authorisation and technical access controls.

Relevance to training and awareness

Deemed exports: foreign-person employees' access to controlled technical data

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
Employees
10,000 or more
Mitigating circumstances
The allegations are based on facts that the group itself disclosed to the DDTC.

Original amount 51,000,000 USD, converted at the ECB reference rate of 28 Feb 2024.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 28 Feb 2026 · Direct link

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20 Feb 2024 a US steel fabrication businessSteel fabricator: OSHA proposes $348,683 over alleged deficiencies despite warning from its own consultant USAWorkplace safety and accidentsanonymised €322,795

According to the U.S. Occupational Safety and Health Administration (OSHA), inspectors responding to a complaint found at a family-run steel fabrication business in New Jersey, among other things, missing medical evaluations for respirator users, uninspected overhead cranes, incorrectly used welding screens and missing chemical hazard training; according to OSHA, a safety consultant had identified the deficiencies months earlier. OSHA proposed penalties of $348,683 (4 violations classified as wilful, 7 as serious); the violations are alleged, and the company has contested the citations.

What organisations can take from it

A consultant's report identifying known deficiencies that is not acted upon will later serve as evidence of wilfulness.

Relevance to training and awareness

Hazardous substance training for new employees

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 1910.134, 1910.179, 1910.1200 u. a.
Action
Fine
Status of proceedings
under appeal
Sector
Steel and metals
Culpability
intentional
Published
20 Feb 2024

Original amount 348,683 USD, converted at the ECB reference rate of 20 Feb 2024.

Checked against the official source on 28 Sep 2026 · Version 5 · Company name anonymised since 20 Feb 2026 · Direct link

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8 Feb 2024 three US trading companiesThree US trading companies: 1 million USD – warehouse workers without daily overtime and genuine breaks USA, CAWorking timeanonymised €929,541

Warehouse and sales staff were not paid for all hours worked, received overtime premiums only after 40 hours a week instead of after eight hours a day, and had to remain available to customers during rest and meal breaks. Following citations issued in 2021, the California Labor Commissioner’s Office agreed a settlement of 1 million USD for 107 employees.

What organisations can take from it

A break during which employees must remain available is legally working time – break arrangements must ensure genuine interruptions.

Relevance to training and awareness

Breaks are time off work – not standby

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 (Daily Overtime, Meal and Rest Periods, Mindestlohn)
Action
Other
Status of proceedings
final
Sector
Retail and e-commerce

Original amount 1,000,000 USD, converted at the ECB reference rate of 8 Feb 2024.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 8 Feb 2026 · Direct link

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16 Jan 2024 a large US broker-dealerSEC: broker-dealer pays 18 million US dollars over gagging clauses in client settlements USARetaliation against whistleblowersanonymised €16.5m

From March 2020 to July 2023, the broker-dealer had hundreds of retail clients who received credits or settlement payments of more than 1,000 US dollars sign confidentiality agreements that permitted responses to SEC enquiries but prohibited voluntary contact with the SEC. The U.S. Securities and Exchange Commission (SEC) imposed 18 million US dollars.

What organisations can take from it

Confidentiality clauses with clients must not exclude voluntary reporting to supervisory authorities either.

Relevance to training and awareness

Whistleblower protection in settlement and confidentiality agreements

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
Financial services and insurance
Employees
10,000 or more
Published
16 Jan 2024

Original amount 18,000,000 USD, converted at the ECB reference rate of 16 Jan 2024.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 16 Jan 2026 · Direct link

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10 Jan 2024 a US engine manufacturing groupUS engine manufacturer: 1.675 billion USD civil penalty for defeat devices in pickups USAEmissions and permitsanonymised €1.53bn

The engine manufacturer programmed the engine software so that emission controls were reduced or switched off during normal driving (around 630,000 heavy-duty pickups of one vehicle maker from model years 2013–2019) and failed to disclose auxiliary emission control devices in a further approximately 330,000 vehicles. Civil penalty of 1.675 billion USD – the highest ever under the Clean Air Act – plus recall and mitigation measures, totalling around 2 billion USD.

What organisations can take from it

Software functions that affect emissions behaviour must be fully disclosed in the type approval process.

Authority / court
U.S. Environmental Protection Agency / U.S. Department of Justice (U.S. District Court, District of Columbia)
Area of law
Environment and sustainability · Emissions and permits
Legal basis
Clean Air Act
Action
Fine
Status of proceedings
unknown
Sector
Automotive
Employees
10,000 or more

Original amount 1,675,000,000 USD, converted at the ECB reference rate of 10 Jan 2024.

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

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21 Dec 2023 a New York insurerOFAC: USD 466,200 settlement with US insurer over policies for a blocked company USABreaches of sanctions and embargoesanonymised €424,474

An insurer based in New York State is paying USD 466,200 under a settlement with OFAC for 39 apparent violations of the Ukraine-/Russia-related sanctions. According to OFAC's findings, between May 2018 and July 2020 the company processed transactions totalling USD 315,891 relating to four insurance policies of a Panamanian company owned by a person on the SDN List and therefore itself blocked. According to OFAC, it had been known within the company since 2010 that the policies covered that person's property. OFAC treated the apparent violations as non-egregious and not voluntarily self-disclosed; the base penalty was USD 666,000. Summarised in our own words.

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. § 589.201(a)(4)(iii) (39 mutmaßliche Verstöße); Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
21 Dec 2023

Original amount 466,200 USD, converted at the ECB reference rate of 21 Dec 2023.

Checked against the official source on 28 Sep 2026 · Version 5 · Company name anonymised since 21 Dec 2025 · Direct link

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19 Dec 2023 a US pharmacy chainFTC: five-year ban on AI facial recognition for pharmacy chain after false alerts USAAI systemsanonymised Order

According to the U.S. Federal Trade Commission (FTC), the pharmacy chain used AI facial recognition in hundreds of stores from 2012 to 2020, which falsely flagged customers – particularly women and people of colour – as shoplifters; accuracy was neither tested in advance nor monitored, and employees were not adequately trained. Under the proposed settlement order (subject to approval by the bankruptcy court and the federal court), the chain may not use the technology for surveillance for five years and must delete images and algorithms developed from them; in addition, the FTC alleges a violation of its 2010 data security order.

What organisations can take from it

AI systems with consequences for people need testing for error rates, ongoing monitoring and trained staff who critically review matches.

Relevance to training and awareness

Training on handling AI matches and false alerts

Missing or inadequate training played a role in the decision.

Authority / court
Federal Trade Commission
Area of law
AI and digital regulation · AI systems
Legal basis
FTC Act Section 5; Verstoß gegen FTC-Datensicherheitsanordnung von 2010
Action
Order
Status of proceedings
unknown
Sector
Retail and e-commerce
Employees
10,000 or more
Repeat case
yes
Published
19 Dec 2023

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 19 Dec 2025 · Direct link

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13 Dec 2023 a US crypto trading platformOFAC: USD 1.21 million settlement with US crypto platform over transactions by users in Crimea USABreaches of sanctions and embargoesanonymised €1.12m

A San Francisco crypto trading platform agreed to a settlement with OFAC of USD 1,207,830. According to OFAC's findings, between April 2020 and May 2022 the company processed 989 transactions worth around USD 1.25 million for users ordinarily resident in Crimea. Most of the 89 accounts concerned gave Russia as the country of residence but listed addresses in Crimea; screening did not pick up the address field. OFAC treated the apparent violations as non-egregious and not voluntarily self-disclosed; the base penalty was USD 3,097,000. In view of the company's financial circumstances, USD 300,000 of the settlement amount is suspended as long as it meets its compliance commitments; a further USD 300,000 is treated as satisfied if the company invests that amount in additional sanctions controls. Summarised in our own words.

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. § 589.207 (989 mutmaßliche Verstöße); Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
13 Dec 2023

Original amount 1,207,830 USD, converted at the ECB reference rate of 13 Dec 2023.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 13 Dec 2025 · Direct link

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8 Dec 2023 a US exchange operatorOFAC: USD 4.04 million settlement with US exchange operator over dealings of its former Armenian exchange subsidiary USABreaches of sanctions and embargoesanonymised €3.75m

A New York exchange operator is paying USD 4,040,923 under a settlement with OFAC for the conduct of its former Armenian subsidiary, which operated the Armenian Stock Exchange. According to OFAC's findings, between December 2012 and September 2014 the subsidiary processed 151 transactions with a face value of around USD 227.9 million on its trading platforms with the Armenian subsidiary of a designated Iranian state-owned bank, thereby knowingly exporting services to Iran and the Government of Iran. OFAC treated the apparent violations as non-egregious and voluntarily self-disclosed. Summarised in our own words.

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. § 560.215 (151 mutmaßliche Verstöße); Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
8 Dec 2023

Original amount 4,040,923 USD, converted at the ECB reference rate of 8 Dec 2023.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 8 Dec 2025 · Direct link

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27 Nov 2023 a US title insurerNYDFS: $1 million against US title insurer over open document links USA, NYSecurity measures and risk managementanonymised €913,159

An application of the insurer generated links to transaction documents without login and without an expiry date; according to a journalist, by changing the sequential document number, 885 million documents containing, among other things, social security and bank data could be retrieved. Users were told not to send sensitive data, but there were no technical barriers. The penalty was imposed by the New York State Department of Financial Services (NYDFS).

What organisations can take from it

Instructions to users do not replace technical controls – sharing links need authentication and an expiry date.

Relevance to training and awareness

Classification and sending of sensitive documents

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 §§ 500.3, 500.7 (Cybersecurity Regulation)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Culpability
negligent

Original amount 1,000,000 USD, converted at the ECB reference rate of 27 Nov 2023.

Sources

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 27 Nov 2025 · Direct link

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21 Nov 2023 an international crypto exchangeOFAC: USD 968.6 million settlement with crypto exchange over matching trades between US users and users in sanctioned jurisdictions USABreaches of sanctions and embargoesanonymised €884.2m

A Cayman Islands-registered crypto exchange is paying USD 968,618,825 under a settlement with OFAC for 1,667,153 apparent violations of multiple sanctions programmes. According to OFAC's findings, from August 2017 to October 2022 its trading platform matched virtual currency trades worth around USD 706 million between US users and users in sanctioned jurisdictions or blocked persons. According to OFAC, senior management knew of and permitted the presence of US users and users from sanctioned jurisdictions on the platform, misled third parties about its controls and encouraged users to circumvent its own controls. OFAC treated the case as egregious and not voluntarily self-disclosed; the base penalty equalled the statutory maximum. The company reached parallel resolutions with the DOJ, FinCEN and the CFTC; USD 898,618,825 of the OFAC amount is deemed satisfied by the payment to the DOJ. The company must also retain an independent compliance monitor for five years. Summarised in our own words.

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. § 560.204; Syrian Sanctions Regulations, 31 C.F.R. § 542.207; North Korea Sanctions Regulations, 31 C.F.R. §§ 510.206, 510.212, E.O. 13722; Ukraine-/Russia-Related Sanctions Regulations, 31 C.F.R. §§ 589.207, 589.213, E.O. 13685; Cuban Assets Control Regulations, 31 C.F.R. § 515.201; E.O. 14065; IEEPA § 206(a); Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
21 Nov 2023

Original amount 968,618,825 USD, converted at the ECB reference rate of 21 Nov 2023.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 21 Nov 2025 · Direct link

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21 Nov 2023 a Californian construction companyCalifornian construction company: over 1 million USD – up to 68 hours a week without overtime pay USA, CAWorking timeanonymised Other

Employees of the Californian construction company regularly worked 45 to 68 hours a week without being paid for overtime; there was also no paid sick leave and no proper wage statements. The California Labor Commissioner’s Office concluded a settlement with the company of more than 1 million USD for the benefit of 249 construction workers.

What organisations can take from it

Anyone allowing long working weeks must also record and pay for them in full – systematic unrecorded overtime comes to light in every wage audit.

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 (Überstunden, Paid Sick Leave, Lohnabrechnung)
Action
Other
Status of proceedings
final
Sector
Construction and real estate

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 21 Nov 2025 · Direct link

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15 Nov 2023 a US online lenderCFPB: online lender pays 15 million USD after breaching an earlier order USAConsumer protection and online retailanonymised €13.8m

According to the CFPB, the online lender (operating two brands) continued to debit consumer accounts without valid consent despite a 2019 order, including by using account details from purchased loan applications, and also breached the prohibition of unfair and deceptive practices. The new order supersedes the 2019 order, imposes a fine of 15 million USD and requires redress; in September 2025 the CFPB terminated it early after the fine had been paid.

What organisations can take from it

After a regulatory order, compliance must be actively monitored; a repeat breach costs many times the first sanction.

Relevance to training and awareness

Collecting customer payments only with valid authorisation

Authority / court
Consumer Financial Protection Bureau (CFPB)
Area of law
Consumer protection and online retail
Legal basis
Consumer Financial Protection Act of 2010, §§ 1031, 1036 (12 U.S.C. §§ 5531, 5536); Verstoß gegen die Consent Order 2019-BCFP-0003
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Repeat case
yes
Published
15 Nov 2023

Original amount 15,000,000 USD, converted at the ECB reference rate of 15 Nov 2023.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 15 Nov 2025 · Direct link

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8 Nov 2023 a major US bankCFPB: 25.9 million USD against major bank over credit card application discrimination USAConsumer protection and online retailanonymised €23m

According to the CFPB, from at least 2015 to 2021 the bank discriminated against credit card applicants on the basis of Armenian national origin and did not give accurate reasons for rejections, in breach of the Equal Credit Opportunity Act and Regulation B. The order required 1.4 million USD in redress and a fine of 24.5 million USD; in October 2025 the CFPB terminated it early after the payments and remedial measures had been made. The authority allegedly made the findings set out here; this account is not based on a final judgment. The amount field records only the civil monetary penalty.

What organisations can take from it

Credit decisions must never be linked to origin markers such as names or places of residence, and every rejection needs its actual reason.

Relevance to training and awareness

Non-discriminatory lending and reasons for rejections

Authority / court
Consumer Financial Protection Bureau (CFPB)
Area of law
Consumer protection and online retail
Legal basis
Equal Credit Opportunity Act (15 U.S.C. § 1691 ff.) und Regulation B; Consumer Financial Protection Act of 2010
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Published
8 Nov 2023

Original amount 24,500,000 USD, converted at the ECB reference rate of 8 Nov 2023.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 8 Nov 2025 · Direct link

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6 Nov 2023 a US prepaid rewards payment companyOFAC: USD 206,213 settlement with payments company over redemption of reward cards in sanctioned regions USABreaches of sanctions and embargoesanonymised €191,987

An Illinois payments company is paying USD 206,213 under a settlement with OFAC for 12,391 apparent violations of the sanctions on Crimea, Iran, Syria and Cuba. According to OFAC's findings, between November 2017 and July 2022 the company, which runs prepaid reward card programmes, redeemed cards worth a total of USD 549,134.89 for recipients apparently located in those jurisdictions. Addresses were screened, but IP addresses and email suffixes were not comprehensively checked for sanctioned jurisdictions. OFAC treated the apparent violations as non-egregious and voluntarily self-disclosed; the base penalty was USD 274,950. Summarised in our own words.

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. § 515.201; Iranian Transactions and Sanctions Regulations, 31 C.F.R. § 560.204; Ukraine-/Russia-Related Sanctions Regulations, 31 C.F.R. § 589.207; Syrian Sanctions Regulations, 31 C.F.R. § 542.207; Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
6 Nov 2023

Original amount 206,213 USD, converted at the ECB reference rate of 6 Nov 2023.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 6 Nov 2025 · Direct link

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23 Oct 2023 a US grain merchandiserGrain merchandiser: 3 million USD for attempted manipulation of oats futures USAMarket abuse and insider dealinganonymised €2.83m

The CFTC fined a grain merchandiser from Minnesota 3 million USD for attempted manipulation of the July 2016 and March 2017 oats futures contracts. According to the order, with the knowledge of senior personnel, the merchandiser built up large long positions close to the speculative position limits, held them into the delivery period and took delivery of oats, intending to raise the futures price and obtain better-quality oats at lower delivery prices. The CFTC recognised significant remedial measures.

What organisations can take from it

Holding futures positions into the delivery period in order to influence the price is manipulation – even in small agricultural markets.

Relevance to training and awareness

Market manipulation in commodity and futures trading

Missing or inadequate training played a role in the decision.

Authority / court
U.S. Commodity Futures Trading Commission (CFTC)
Area of law
Capital markets and financial supervision · Market abuse and insider dealing
Legal basis
Section 9(a)(2) Commodity Exchange Act (7 U.S.C. § 13(a)(2))
Action
Fine
Status of proceedings
final
Sector
Food and agriculture
Culpability
intentional
Mitigating circumstances
According to the order, the merchandiser revised its policies and procedures and introduced training for all personnel trading commodity interests.
Published
23 Oct 2023

Original amount 3,000,000 USD, converted at the ECB reference rate of 23 Oct 2023.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 23 Oct 2025 · Direct link

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16 Oct 2023 a US commercial bankFederal Reserve: USD 14.5 million against US commercial bank over prepaid accounts USACustomer due diligenceanonymised €13.7m

The Federal Reserve issued a cease and desist order and a civil money penalty of USD 14,478,676 against a US commercial bank. In 2020 the bank opened prepaid card accounts through an external programme manager without adequately verifying applicants' identities under the Customer Identification Program rule, and did not properly oversee this third-party programme. Perpetrators used the accounts with stolen identities to obtain more than USD 300 million in state unemployment benefits.

What organisations can take from it

In fintech partnerships the bank remains responsible for identity verification and fraud prevention, even when a programme manager distributes the accounts.

Relevance to training and awareness

Identity verification and third-party risk management in fintech programmes

Authority / court
Board of Governors of the Federal Reserve System
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
Customer Identification Program Rule, 31 C.F.R. § 1020.220; Federal Deposit Insurance Act (12 U.S.C. § 1818(b) und (i))
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
19 Oct 2023

Original amount 14,478,676 USD, converted at the ECB reference rate of 16 Oct 2023.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 16 Oct 2025 · Direct link

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29 Sep 2023 a US investment bankInvestment bank: 30 million USD over swap reporting failures and deficient supervision USADisclosure and reporting obligationsanonymised €28.3m

The CFTC fined the swap dealer 30 million USD. Since the reporting requirements took effect, the bank had failed to report a significant portion of its swap data accurately or on time to a swap data repository – more than 20 million swaps were back-reported – and since 2013 had given counterparties inaccurate pre-trade mid-market marks, or none at all, on more than one million occasions. According to the order, the cause was that CFTC compliance was not adequately resourced and prioritised; the fine was reduced for substantial cooperation, and the bank must implement a remediation plan and retain a consultant.

What organisations can take from it

New reporting obligations need adequate staffing and priority within compliance; otherwise errors accumulate into the millions over the years.

Authority / court
U.S. Commodity Futures Trading Commission (CFTC)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Sections 2(a)(13)(F), (G) und 4s(h)(1) Commodity Exchange Act; CFTC Regulations 23.431(a)(3)(i), 23.602(a), 43.3(a)(1), 45.3(b)(1), 45.4(c) und 45.6
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Substantial cooperation that materially advanced the investigation, and remediation already under way, including additional training and pre-trade booking prompts; the fine was reduced accordingly.
Published
29 Sep 2023

Original amount 30,000,000 USD, converted at the ECB reference rate of 29 Sep 2023.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 29 Sep 2025 · Direct link

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29 Sep 2023 the US subsidiary bank of a foreign bankFinCEN: USD 15 million against a foreign bank's US subsidiary over monitoring backlogs USASuspicious activity reportsanonymised €14.2m

FinCEN imposed a civil money penalty of allegedly USD 15 million on the US subsidiary bank of a foreign bank. Between April 2016 and March 2021 the bank did not maintain an adequate AML programme, at times built up substantial backlogs in transaction monitoring and did not report suspicious transactions accurately and on time.

What organisations can take from it

Growing alert backlogs in transaction monitoring are a warning sign to which management and the board must respond with additional resources.

Relevance to training and awareness

Backlogs in transaction monitoring and timely suspicious activity reporting

Authority / court
Financial Crimes Enforcement Network (FinCEN), U.S. Department of the Treasury
Area of law
Money laundering and terrorist financing · Suspicious activity reports
Legal basis
31 U.S.C. § 5318(h), § 5318(g); 31 C.F.R. §§ 1020.210, 1020.320
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
29 Sep 2023

Original amount 15,000,000 USD, converted at the ECB reference rate of 29 Sep 2023.

Sources

Checked against the official source on 7 Oct 2026 · Company name anonymised since 29 Sep 2025 · Direct link

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28 Sep 2023 a US outdoor advertising groupUS outdoor advertising group: 26.1 million USD – gifts and hospitality for Chinese officials USABribery of public officialsanonymised €24.8m

From at least 2012 to 2017, the group's Chinese majority-owned subsidiary bribed officials with expensive gifts and hospitality and used sham intermediaries and false invoices to fund concealed consultants in order to obtain advertising space, for example at bus stops; the payments were booked as entertainment, cleaning and customer development expenses. Despite repeated warnings from internal audit, adequate controls were lacking until 2019; the group paid 16,355,567 USD in disgorgement, 3,760,920 USD in interest and a civil penalty of 6 million USD (a total of 26,116,487 USD).

What organisations can take from it

Internal audit findings on entertainment and consultancy costs in high-risk markets must lead to immediate controls.

Relevance to training and awareness

Gifts and hospitality for public officials; correct booking

Authority / court
U.S. Securities and Exchange Commission (SEC)
Area of law
Bribery and corruption · Bribery of public officials
Legal basis
Foreign Corrupt Practices Act (Anti-Bribery, Books and Records, Internal Accounting Controls)
Action
Fine
Status of proceedings
final
Sector
Media and online platforms

Original amount 26,116,487 USD, converted at the ECB reference rate of 28 Sep 2023.

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

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26 Sep 2023 a US manufacturer of hydrogen commercial vehiclesCommercial vehicle manufacturer: fictitious vehicle sales after SPAC merger – 25 million USD USADisclosure and reporting obligationsanonymised €23.6m

The manufacturer of hydrogen commercial vehicles misled investors about customer relationships and sales, reported 87 vehicles sold for 2021 when the actual number was zero, and showed a misleading video of a purportedly hydrogen-powered vehicle. The company is paying 25 million USD.

What organisations can take from it

After a SPAC merger, the same duties of truthfulness apply as for any issuer – letters of intent must not be sold as revenue.

Authority / court
U.S. Securities and Exchange Commission (SEC)
Area of law
Capital markets and financial supervision · Disclosure and reporting obligations
Legal basis
Antifraud- und weitere Vorschriften der US-Wertpapiergesetze
Action
Fine
Status of proceedings
unknown
Sector
Automotive
Employees
250 to 999
Liability of senior managers
Measures against individuals are not reported here.

Original amount 25,000,000 USD, converted at the ECB reference rate of 26 Sep 2023.

Checked against the official source on 28 Sep 2026 · Version 6 · Company name anonymised since 26 Sep 2025 · Direct link

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25 Sep 2023 a US subsidiary of a German asset managerUS asset manager: 19 million USD for misleading ESG statements USAMisleading environmental and sustainability claimsanonymised €17.9m

From 2018 until the end of 2021, the subsidiary of a German major bank presented ESG as part of its ‘DNA’ but did not implement the ESG integration policies it had promised. It is paying 19 million USD for the ESG misstatements; in separate proceedings over deficiencies in its anti-money laundering programme, a further 6 million USD was added.

What organisations can take from it

ESG marketing statements must be backed by processes that are actually practised and documented; otherwise they become a regulatory risk.

Relevance to training and awareness

Truthful sustainability communication in sales and marketing

Authority / court
U.S. Securities and Exchange Commission (SEC)
Area of law
Environment and sustainability · Misleading environmental and sustainability claims
Legal basis
Sections 206(2), 206(4) Investment Advisers Act; Rules 206(4)-7 und 206(4)-8
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
25 Sep 2023

Original amount 19,000,000 USD, converted at the ECB reference rate of 25 Sep 2023.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 25 Sep 2025 · Direct link

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21 Sep 2023 a New York bankOFAC: USD 31,867.90 settlement with New York bank over an account for account holders in Iran USABreaches of sanctions and embargoesanonymised €29,965

A New York-based bank is paying USD 31,867.90 under a settlement with OFAC for 30 apparent violations of the Iran sanctions. According to OFAC's findings, the bank maintained a certificate of deposit account for two individuals resident in Iran for around 26 years and processed 30 transactions totalling USD 91,051.13 through it between June 2017 and March 2021, although it knew their Iranian address. According to OFAC, a screening alert in 2016 was wrongly cleared as a permissible personal remittance. OFAC treated the apparent violations as non-egregious and voluntarily self-disclosed; the base penalty was USD 45,526. Summarised in our own words.

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. § 560.204 (30 mutmaßliche Verstöße); Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
21 Sep 2023

Original amount 31,867.9 USD, converted at the ECB reference rate of 21 Sep 2023.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 21 Sep 2025 · Direct link

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15 Sep 2023 an international bankFinCEN: USD 15 million against an international bank over correspondent banking and SARs USACustomer due diligenceanonymised €14.1m

FinCEN imposed a civil money penalty of allegedly USD 15 million on an international bank. Between October 2015 and May 2022 the bank failed to report suspicious transactions, did not maintain an adequate due diligence programme for correspondent accounts of foreign financial institutions and, from March 2021, had no effective AML programme. The bank, which is being wound up, must also surrender its licence.

What organisations can take from it

Correspondent relationships with foreign institutions in high-risk regions require dedicated due diligence that is actually applied, and ongoing monitoring.

Relevance to training and awareness

Due diligence in correspondent banking relationships in high-risk regions

Authority / court
Financial Crimes Enforcement Network (FinCEN), U.S. Department of the Treasury
Area of law
Money laundering and terrorist financing · Customer due diligence
Legal basis
31 U.S.C. § 5318(g), (h), (i); 31 C.F.R. §§ 1020.320, 1010.610, 1020.210
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
15 Sep 2023

Original amount 15,000,000 USD, converted at the ECB reference rate of 15 Sep 2023.

Sources

Checked against the official source on 7 Oct 2026 · Company name anonymised since 15 Sep 2025 · Direct link

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13 Sep 2023 a US subsidiary of a Japanese vehicle and engine manufacturerUS subsidiary of engine maker: almost USD 8m CARB settlement over small engine emissions USA, CaliforniaEmissions and permitsanonymised €5.31m

CARB reached a settlement with the US subsidiary of a Japanese vehicle and engine manufacturer totalling 7,968,419 USD for breaches of the rules on small off-road engines (SORE) and on evaporative emissions: a civil penalty of 5,694,452 USD and 2,273,967 USD for four environmental projects. The company had obtained a variance for several engine families, mostly generators, whose carbon canisters did not meet capacity requirements, but failed to meet its conditions; after the variance was revoked, all units sold under it counted as non-compliant. It is the third SORE enforcement action against the company within four years. The authority allegedly made the findings set out here; this account is not based on a final judgment. The amount field records only the civil monetary penalty.

What organisations can take from it

Companies selling under a conditional variance must monitor compliance with its terms continuously – if it lapses, every sale becomes non-compliant.

Relevance to training and awareness

Complying with conditions attached to variances

Authority / court
California Air Resources Board (CARB)
Area of law
Environment and sustainability · Emissions and permits
Legal basis
CARB Small Off-Road Engine (SORE) Regulation; Evaporative Emissions Regulations
Action
Fine
Status of proceedings
final
Sector
Manufacturing and mechanical engineering
Repeat case
yes
Mitigating circumstances
According to CARB, the company cooperated in resolving the allegations.
Published
13 Sep 2023

Original amount 5,694,452 USD, converted at the ECB reference rate of 13 Sep 2023.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 13 Sep 2025 · Direct link

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8 Sep 2023 a US cleantech companySEC: US cleantech firm pays 225,000 US dollars over award waivers USARetaliation against whistleblowersanonymised €210,202

From February 2020 to March 2023, the unlisted cleantech company (around 236 employees) had 22 departing employees waive awards for reports to authorities. After contact by the U.S. Securities and Exchange Commission (SEC), the company amended the agreements and informed those affected; the penalty amounted to 225,000 US dollars.

What organisations can take from it

Unlisted companies are also subject to the SEC's whistleblower protection rules.

Relevance to training and awareness

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
Chemicals and pharmaceuticals
Employees
50 to 249
Mitigating circumstances
Revision of the separation agreements and information provided to the former employees affected
Published
8 Sep 2023

Original amount 225,000 USD, converted at the ECB reference rate of 8 Sep 2023.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 8 Sep 2025 · Direct link

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29 Aug 2023 a US industrial manufacturerOFAC: USD 9.62m settlement with US manufacturer over sale of reflective sheeting to an Iranian police entity USABreaches of sanctions and embargoesanonymised €8.9m

A US manufacturer based in Minnesota is paying USD 9,618,477 under a settlement with OFAC for 54 apparent violations of the Iran sanctions. According to OFAC's findings, between 2016 and 2018 its Swiss subsidiary knowingly sold reflective licence plate sheeting via a German reseller to an entity controlled by Iran's Law Enforcement Forces; a US person employed by a foreign subsidiary was closely involved. Such dealings were expressly excluded from the general licence then available to foreign subsidiaries. OFAC treated the apparent violations as egregious but voluntarily self-disclosed; the base penalty was USD 13,740,682. OFAC signed the settlement agreement on 29 August 2023 and published it on 21 September 2023. Summarised in our own words.

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. §§ 560.204, 560.206, 560.215 (54 mutmaßliche Verstöße); Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A
Action
Fine
Status of proceedings
final
Sector
Manufacturing and mechanical engineering
Published
21 Sep 2023

Original amount 9,618,477 USD, converted at the ECB reference rate of 29 Aug 2023.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 29 Aug 2025 · Direct link

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28 Aug 2023 a US housing listings platformFTC and six states: settlement with housing platform over tens of thousands of purchased reviews USAFake reviewsanonymised €1.48m

According to the Federal Trade Commission (FTC, the US consumer protection authority) and six state attorneys general, the housing listings platform flooded the internet with tens of thousands of purchased four- and five-star reviews and charged fees for access to listings that often turned out to be fake. The settlement order filed with the federal court in New York permanently bans the platform from paid or incentivised reviews; the judgment of 36.2 million USD plus 10.9 million USD in civil penalties payable to the states is suspended after a joint payment of 1.6 million USD by the liable parties.

What organisations can take from it

Do not buy reviews; this can lead to permanent bans and monitoring duties for all marketing partners.

Relevance to training and awareness

Buying reviews and monitoring affiliate partners

Authority / court
Federal Trade Commission (FTC) mit den Attorneys General von New York, Kalifornien, Colorado, Florida, Illinois und Massachusetts
Area of law
Consumer protection and online retail · Fake reviews
Legal basis
Section 5 FTC Act; Verbraucherschutzgesetze der beteiligten Bundesstaaten
Action
Order
Status of proceedings
unknown
Sector
Media and online platforms
Mitigating circumstances
Payment obligation suspended down to 1.6 million USD owing to limited financial capacity.
Liability of senior managers
Measures against individuals are not reported here.
Published
28 Aug 2023

Original amount 1,600,000 USD, converted at the ECB reference rate of 28 Aug 2023.

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

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25 Aug 2023 a US conglomerateUS conglomerate: foreign trips for Chinese hospital officials cost 6.6 million USD USAGifts, hospitality and benefitsanonymised €6.09m

From 2014 to 2018, employees of the group's Chinese subsidiary invited healthcare officials of state-owned customers abroad to purported conferences and training courses that in reality often consisted of sightseeing and entertainment; payment was made via a complicit travel agency. Payment of 3,538,897 USD in disgorgement, 1,042,721 USD in interest and a penalty of 2 million USD.

What organisations can take from it

Training trips for public-sector customers require a professional programme, prior approval and supporting documentation – tourism components are impermissible benefits.

Relevance to training and awareness

Invitations to events and trips 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
Action
Fine
Status of proceedings
final
Sector
Healthcare
Employees
10,000 or more
Culpability
intentional
Mitigating circumstances
Prompt self-report upon becoming aware, cooperation (including witnesses and documents) and extensive remedial measures.
Published
25 Aug 2023

Original amount 6,581,618 USD, converted at the ECB reference rate of 25 Aug 2023.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 25 Aug 2025 · Direct link

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21 Aug 2023 a US generic drug manufacturerDOJ: generics manufacturer pays 225 million USD criminal penalty over generic drug price fixing USACartels and collusionanonymised €206.3m

In a Deferred Prosecution Agreement, the manufacturer admitted to three conspiracies involving price fixing, customer allocation and bid rigging for generic drugs (including pravastatin). The manufacturer is paying a criminal penalty of 225 million USD in instalments, donating medicines worth 50 million USD and must divest its pravastatin business under the supervision of a monitor.

What organisations can take from it

In addition to penalties running into millions, antitrust violations can force companies to divest entire product lines.

Relevance to training and awareness

Agreements among generic drug manufacturers on prices and customers

Authority / court
U.S. Department of Justice, Antitrust Division
Area of law
Competition law · Cartels and collusion
Legal basis
15 U.S.C. § 1 (Sherman Act)
Action
Fine
Status of proceedings
unknown
Sector
Chemicals and pharmaceuticals
Employees
10,000 or more

Original amount 225,000,000 USD, converted at the ECB reference rate of 21 Aug 2023.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 21 Aug 2025 · Direct link

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21 Jul 2023 two Swiss major banks (acquiring and acquired bank)Federal Reserve: USD 268.5 million against Swiss major banks for risk failures USAOrganisational requirementsanonymised €241.4m

The Federal Reserve issued a cease and desist order and a civil money penalty of USD 268,494,109.20 against an acquired Swiss major bank and the acquiring Swiss banking group as successor to the acquired bank's group parent. The grounds were unsafe or unsound counterparty credit risk management practices towards a family office and longstanding weaknesses in US risk management, including liquidity, model and third-party risk and data quality.

What organisations can take from it

Warning signs regarding major clients must be escalated by the independent risk function and enforced through limits or collateral.

Relevance to training and awareness

Counterparty risk and escalation of warning signs in risk management

Authority / court
Board of Governors of the Federal Reserve System
Area of law
Capital markets and financial supervision · Organisational requirements
Legal basis
Section 8(b) und 8(i)(2)(B) Federal Deposit Insurance Act (12 U.S.C. § 1818(b) und (i)(2)(B)); 12 C.F.R. §§ 252.155–252.157 (Regulation YY)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Published
24 Jul 2023

Original amount 268,494,109.2 USD, converted at the ECB reference rate of 21 Jul 2023.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 21 Jul 2025 · Direct link

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13 Jul 2023 a German major bank and its US entitiesFederal Reserve: USD 186 million against German major bank for delayed AML remediation USAInternal controlsanonymised €166.7m

The Federal Reserve issued a cease and desist order and a civil money penalty of USD 186,392,035 against a German major bank, its branch in New York and US entities. Of this, USD 140,192,035 relates to violations of the supervisory orders of 2015 (sanctions compliance) and 2017 (anti-money laundering), on which the bank had made insufficient progress, and USD 46,200,000 to governance and AML control failures in its former correspondent relationship with the Estonian branch of a Danish major bank, for which the US subsidiary cleared more than USD 267 billion in transactions between 2007 and 2015.

What organisations can take from it

A firm under a supervisory order must demonstrably complete its remediation – lack of progress becomes a ground for sanctions in itself.

Relevance to training and awareness

Implementing supervisory remediation requirements and correspondent banking risks

Authority / court
Board of Governors of the Federal Reserve System
Area of law
Money laundering and terrorist financing · Internal controls
Legal basis
Section 8(b) und 8(i)(2) Federal Deposit Insurance Act (12 U.S.C. § 1818); Anordnungen des Board of Governors vom 04.11.2015 und 26.05.2017
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Repeat case
yes
Published
19 Jul 2023

Original amount 186,392,035 USD, converted at the ECB reference rate of 13 Jul 2023.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 13 Jul 2025 · Direct link

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11 Jul 2023 a major US bankCFPB: major bank pays 140.4 million USD over repeat fees on returned payments USAConsumer protection and online retailanonymised €54.6m

The bank charged a 35 USD fee for cheques and ACH debits returned for insufficient funds and charged it again when the payee re-presented the same transaction; the CFPB found these repeat fees (September 2018 to February 2022) to be unfair. The order requires refunds of at least 80.4 million USD and a fine of 60 million USD; the parallel fine imposed by the banking supervisor OCC (60 million USD) and a second CFPB order on credit cards are not included. The authority allegedly made the findings set out here; this account is not based on a final judgment. The amount field records only the civil monetary penalty.

What organisations can take from it

Per-transaction fees must be built so that the same transaction cannot be charged more than once.

Relevance to training and awareness

Charges for returned payments and repeat fees

Authority / court
Consumer Financial Protection Bureau (CFPB)
Area of law
Consumer protection and online retail
Legal basis
Consumer Financial Protection Act of 2010, §§ 1031, 1036 (12 U.S.C. §§ 5531, 5536)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Employees
10,000 or more
Published
11 Jul 2023

Original amount 60,000,000 USD, converted at the ECB reference rate of 11 Jul 2023.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 11 Jul 2025 · Direct link

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7 Jul 2023 a US online therapy providerOnline therapy provider: 7.8 million USD after sharing health data for advertising USAMarketing and consentanonymised €7.16m

The FTC finalised its order against an online therapy provider. According to the authority, despite promises of confidentiality the company passed e-mail addresses, IP addresses and answers from its health questionnaire to three social networks and an advertising technology company for advertising purposes without obtaining affirmative consent. The provider pays 7,800,000 USD for partial refunds to customers, may no longer share health data for advertising, must obtain affirmative consent before sharing with certain third parties, must instruct the recipients to delete the data and must set retention periods.

What organisations can take from it

Marketing tools such as audience matching must never be fed with health information unless affirmative consent has been given.

Relevance to training and awareness

Health data and marketing tools; tracking pixels and custom audiences

Authority / court
Federal Trade Commission (FTC)
Area of law
Data protection · Marketing and consent
Legal basis
Section 5(a) FTC Act, 15 U.S.C. § 45(a) (unlautere und irreführende Praktiken)
Action
Disgorgement of profits
Status of proceedings
final
Sector
Healthcare
Published
14 Jul 2023

Original amount 7,800,000 USD, converted at the ECB reference rate of 7 Jul 2023.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 7 Jul 2025 · Direct link

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30 Jun 2023 a US sweepstakes and direct marketing companyFTC: sweepstakes company pays 18.5 million USD over dark patterns in sweepstakes USAMisleading advertising and pricinganonymised €17m

According to the FTC, the company designed its websites to give the impression that an order was necessary to enter its sweepstakes or would increase the chance of winning, falsely told consumers their entries were incomplete, added surprise shipping and handling fees, advertised ordering as "risk free" misleadingly and sent deceptive e-mails. The federal court entered an agreed order with 18.5 million USD for refunds and requirements on how the company must design its online offers in future.

What organisations can take from it

Design tricks suggesting a purchase is required are deception, even if the small print says otherwise.

Relevance to training and awareness

Dark patterns in ordering and entry flows

Authority / court
Federal Trade Commission (FTC)
Area of law
Consumer protection and online retail · Misleading advertising and pricing
Legal basis
Section 5 FTC Act (15 U.S.C. § 45); Section 7(a) CAN-SPAM Act
Action
Disgorgement of profits
Status of proceedings
final
Sector
Retail and e-commerce
Published
26 Jun 2023

Original amount 18,500,000 USD, converted at the ECB reference rate of 30 Jun 2023.

Checked against the official source on 8 Oct 2026 · Company name anonymised since 30 Jun 2025 · Direct link

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27 Jun 2023 a US building products manufacturerOFAC: USD 660,594 settlement with US building products maker over re-exports to Iran by its UAE subsidiary USABreaches of sanctions and embargoesanonymised €603,227

A New Jersey building products manufacturer is paying USD 660,594 under a settlement with OFAC for three apparent violations of the Iran sanctions by its UAE subsidiary According to OFAC's findings, the subsidiary imported building materials from the United States and knowingly re-exported them to Iran; group policy was disregarded and trade documents were falsified. The parent company reported the matter after an internal review. OFAC treated the apparent violations as egregious and voluntarily self-disclosed; the base penalty was USD 1,100,991. OFAC signed the settlement agreement on 27 June 2023 and published it on 16 August 2023. Summarised in our own words.

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. § 560.215 (drei mutmaßliche Verstöße); Vergleich nach den Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A
Action
Fine
Status of proceedings
final
Sector
Construction and real estate
Published
16 Aug 2023

Original amount 660,594 USD, converted at the ECB reference rate of 27 Jun 2023.

Checked against the official source on 28 Sep 2026 · Version 5 · Company name anonymised since 27 Jun 2025 · Direct link

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20 Jun 2023 a Latvian bankLatvian bank: Crimea payments via US correspondent banks USABreaches of sanctions and embargoesanonymised €3.14m

In 2015–2016, a shipping customer of the Latvian bank used online banking from an IP address in Crimea to initiate 386 payments totalling around 3.3 million USD to recipients in Crimea, which were routed through US correspondent banks. Despite a warning from a US bank, the bank relied on false customer statements and did not use the IP data available. The case was pursued by the US Treasury's Office of Foreign Assets Control (OFAC).

What organisations can take from it

Treat alerts from correspondent banks and IP location data as serious warning signs – reassuring customer explanations are no substitute for your own checks.

Relevance to training and awareness

Warning signs in payment transactions (IP geolocation, queries from correspondent banks)

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
OFAC-Sanktionen gegen die Krim-Region (E.O. 13685)
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
20 Jun 2023

Original amount 3,430,900 USD, converted at the ECB reference rate of 20 Jun 2023.

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 20 Jun 2025 · Direct link

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12 Jun 2023 a Chinese manufacturer of printers and printer suppliesUFLPA list: Chinese printer manufacturer and eight subsidiaries added USAForced and child labouranonymised Order

The U.S. Forced Labor Enforcement Task Force (FLETF) added the manufacturer and eight subsidiaries to the Uyghur Forced Labor Prevention Act (UFLPA) Entity List because they work with the Xinjiang government on the recruitment, transport or reception of forced labourers. The company's goods are therefore presumed to have been produced with forced labour on import into the US unless the importer rebuts this.

What organisations can take from it

IT procurement should screen manufacturers of printers, toner and chips against forced labour lists – including subsidiaries.

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
Telecoms, IT and software
Published
12 Jun 2023
Sources

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

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