Compliance Radar

Who was sanctioned, and for what?

Fines, court rulings and incidents from Europe and North America: 718 cases from 32 jurisdictions, each with an official source and checked against that source before publication. Filter by country, area of law and sector. Click a chart to drill down one level.

USA Clear all filters
147cases from 1 jurisdiction
€15bnTotal of monetary amounts (125 cases with an amount)
€4.75bnLargest single case: Purdue Pharma L.P.
€3.7mMedian per case with an amount

Click a bar to drill down one level.

When?

per quarter, by date of decision
Trend
PeriodCasesTotal
Q3 20233€66.5m
Q4 20233€913,159
Q1 20246€1.55bn
Q2 20245€45.2m
Q3 202416€148.4m
Q4 202414€739.2m
Q1 202513€2.66bn
Q2 20258€280.1m
Q3 202515€2.3bn
Q4 202515€1.32bn
Q1 202613€390.3m
Q2 202614€5.23bn
Q3 202622€280.9m

147 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 CEO Ronald Clarke are 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
CEO Ronald Clarke is named in the press release as a party involved.
Published
17 Sep 2026

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

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

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10 Sep 2026 Dompé U.S. Inc.Dompé U.S.: 32 million USD – Medicare patients’ co-payments covered via foundations 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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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, senior engineering officers had oily bilge water pumped overboard via the sewage tank, bypassing the oily water separator, in 2024/2025, manipulated the oil content monitoring and falsified the oil record book, which was presented to the Coast Guard in Philadelphia. The operator and the owner each pleaded guilty to two counts under the Act to Prevent Pollution from Ships (APPS) and are paying a combined 1.75 million USD; in addition, there are four years of probation.

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
Liability of senior managers
Second Engineer Mikhail Tsurikov also pleaded guilty; sentencing scheduled for 10 September 2026.
Published
28 Aug 2026

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

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

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24 Aug 2026 Container Manufacturing Ltd.Small US machinery supplier exported spare parts for can presses to Russia 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 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, co-owner BG Dale Biscoe and employee Randall David Shelton guilty of having fixed prices for erosion control services, allocated contracts regionally and rigged bids on publicly funded road construction projects in Oklahoma (more than 100 million USD) from 2017 to 2023. Sentencing was still pending.

What organisations can take from it

Subcontractors in public road construction are also targeted by prosecutors – up to and including jury convictions of individual employees.

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
Guilty verdict against co-owner BG Dale Biscoe and employee Randall David Shelton
Published
20 Aug 2026

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

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14 Aug 2026 Henkel AG & Co. KGaAHenkel/Liquid Nails: court blocks takeover of Loctite’s main competitor 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 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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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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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, its former CEO Michael Stewart and the businessman Harold Shatz allegedly paid kickbacks and billed Medicare and Medicaid for medically unnecessary genetic tests. The three settlements add up to 36.4 million USD; the laboratory is subject to a Corporate Integrity Agreement.

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
Former CEO pays under a separate settlement.

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

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

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23 Jul 2026 Orchids Builders LLCFlorida roofer: $349,754 for repeatedly missing fall protection USAWorkplace safety and accidents €307,017

On 21.01. and 10 March 2026, the U.S. Occupational Safety and Health Administration (OSHA) found at two residential construction sites in Rockledge that employees of the roofing contractor were working on roofs without fall protection; training records, eye protection when using nail guns and ladders extending sufficiently above the roof edge were also missing. The company had been inspected seven times since 2023, each time with fall protection violations. Proposed: $349,754 (2 wilful, 4 repeat violations).

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 25 Sep 2026 · Direct link

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20 Jul 2026 NeoGenomics Laboratories Inc.NeoGenomics: 9.8 million USD after self-disclosure – discounted consulting for referring physicians 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
The customs broker Carlos Leopoldo Alvelais has pleaded guilty.
Published
17 Jul 2026

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

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

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15 Jul 2026 Vanilla Chip LLC (TruHeight)TruHeight: FTC settlement over allegedly fake reviews for growth supplement 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 payment of 750,000 USD.

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
The co-founders and co-CEOs Eden Stelmach and Justin Rapoport are personally parties to the order.
Published
15 Jul 2026

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

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

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15 Jul 2026 FleetPride Inc.FleetPride: $264,380 after asphyxiation death during tank trailer inspection 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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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, its management company and the owners Kevin Hannah, Donell Burkett and Daniel Hunter Pledger allegedly granted unlawful kickbacks and ordered medically unnecessary tests. Together they paid 30 million USD; the laboratory entered into a Corporate Integrity Agreement.

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
The owners contribute personally as parties to the settlement.

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

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

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16 Jun 2026 Robert Bosch GmbHBosch pays 36 million USD for sensor supplies to Huawei 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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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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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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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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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 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 and their CEO Edward Walker allegedly knowingly overcharged the Air Force and the Navy for welding tables for the modernisation of a large welding facility; the project was financed in part with funds under the Defense Production Act. The settlement under the False Claims Act amounts to 10.5 million USD; a former employee received 1,863,750 USD as a whistleblower.

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
CEO Edward Walker is personally a party to the settlement.
Published
17 Mar 2026

Original amount 10,500,000 USD, converted at the ECB reference rate of 17 Mar 2026.

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

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17 Mar 2026 Balt SAS / Balt USA LLCMedical technology: DOJ declination for Balt SAS after bribery of a hospital physician 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
A former manager of the US subsidiary (David Ferrera) and a consultant (Marc Tilman) were charged with FCPA violations and money laundering.
Published
19 Mar 2026

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

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

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

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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 €34.5m

ADM and former executives had artificially inflated the results of the Nutrition segment through retroactive intra-group rebates and price adjustments in order to show growth targets of 15–20 %. ADM is paying a civil penalty of 40 million USD; two former managers are paying a combined 979,953 USD in disgorgement including interest and 200,000 USD in penalties, while litigation continues against a third.

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
Vince Macciocchi: 404,343 USD disgorgement/interest, 125,000 USD penalty, 3-year officer-and-director bar; Ray Young: 575,610 USD disgorgement/interest, 75,000 USD penalty; action against Vikram Luthar pending

Original amount 41,179,953 USD, converted at the ECB reference rate of 27 Jan 2026.

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

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13 Jan 2026 Maplebear Inc. (Instacart)Instacart pays 60 million USD in FTC settlement over "free delivery" with mandatory fees 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
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 25 Sep 2026 · Direct link

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30 Dec 2025 Rickenbacher Data LLC (Datamasters)CPPA: $45,000 against data broker Datamasters over failure to register 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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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 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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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 and its management are paying 150,000 USD, 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
Founder Robert Epstein and CEO Frank Leonardo III are named in the press release as parties involved.
Published
3 Dec 2025

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

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

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3 Dec 2025 The Boeing Company und Spirit AeroSystems Holdings, Inc.Boeing/Spirit AeroSystems: takeover only with divestiture of Airbus supplier plants 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 the Russian oligarch Suleiman Kerimov via nested structures and continued to manage this investment for four years after his designation in April 2018. The US Treasury's Office of Foreign Assets Control (OFAC) assessed the case as non-egregious and not voluntarily self-disclosed.

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 25 Sep 2026 · Direct link

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20 Nov 2025 Caesars Entertainment, Inc. / Desert Palace, LLC (Caesars Palace)Nevada: 7.8 million USD against Caesars over gambling by an illegal bookmaker 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 the illegal bookmaker Mathew Bowyer and at the same time concluded a settlement of 7.8 million USD with conditions attached to the gaming licences. The conditions relate primarily to improving the AML programme and to additional training and awareness-raising for employees; the Nevada Gaming Commission (NGC) adopted the settlement as its order on 20 November 2025 (Case No. 25-03).

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 25 Sep 2026 · 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).
Liability of senior managers
According to the DOJ, the scheme was directed by the then Guatemalan shareholder and other senior individuals; four individuals had already been charged (not named).
Published
12 Dec 2025

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

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

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31 Oct 2025 Google LLCTexas: Google pays $1.375 billion over location, incognito and biometric data 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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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 owned by the Hong family concealed the employer; the Notice of Final Findings of 21 October 2025 established 438,204 USD, with OptumCare jointly liable as the client.

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
Members of the owning family and an acquaintance cited personally.
Published
24 Nov 2025

Original amount 438,204 USD, converted at the ECB reference rate of 21 Oct 2025.

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

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14 Oct 2025 Farmers Insurance ExchangeNYDFS: $2.775 million against Farmers over unprotected online quoting tools 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 Senior Vice President Neil Lindsay and Vice President Jamil Ghani.
Published
25 Sep 2025

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

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

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

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

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4 Sep 2025 Midri, Inc. (Restaurant J BBQ, Los Angeles)Restaurant J BBQ: 680,238 USD – breaks denied, split shifts without premium 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
Owner Byung Kwan Lee named in the announcement.

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

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

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3 Sep 2025 Fracht FWO Inc.Freight forwarder Fracht FWO chartered blocked Venezuelan airline with Mahan Air jet 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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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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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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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 its former CEO, employees and agents, and sold goods to a blocked Venezuelan company. The US Treasury's Office of Foreign Assets Control (OFAC) considered it an egregious but voluntarily self-disclosed case; there were parallel settlements with the DOJ and BIS, which were taken into account in determining the amount.

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
According to OFAC, the violations were carried out by the former CEO and co-founder as well as former employees.
Published
16 Jun 2025

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

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

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22 May 2025 L3 Technologies Inc.L3 Technologies pays 62 million USD over false cost data for communications technology 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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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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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 director of engineering 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 25 Sep 2026 · Direct link

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

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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 Haas Automation, Inc.Haas Automation: CNC parts and unlock codes for blocked Russian defence companies USABreaches of sanctions and embargoes €2.47m

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. The US Treasury's Office of Foreign Assets Control (OFAC) imposed 1,044,781 USD (eight of the 21 violations egregious, no voluntary self-disclosure); at the same time, Haas paid 1.5 million USD to the US Commerce Department's Bureau of Industry and Security (BIS).

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 2,544,781 USD, converted at the ECB reference rate of 17 Jan 2025.

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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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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

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

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15 Jan 2025 Donghai JA Solar Technology Co., Ltd.UFLPA list: solar manufacturer Donghai JA Solar Technology added 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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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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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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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
Sources

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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

Through an agent and a joint venture partner, AAR paid sham commissions to public officials in order to secure the sale of two Airbus A330s to Nepal Airlines and maintenance services for South African Airways Technical. SEC: 23,451,100 USD in disgorgement and 5,785,524 USD in interest; DOJ criminal penalty of 26,363,029 USD under a Non-Prosecution Agreement.

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.
Liability of senior managers
A former senior employee of an AAR subsidiary, Deepak Sharma (named in the SEC order), was involved.
Published
19 Dec 2024

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

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

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16 Dec 2024 Becton, Dickinson and Company (BD)Becton Dickinson: risks of Alaris infusion pump concealed – 175 million USD 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 25 Sep 2026 · Direct link

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13 Dec 2024 C.H. Robinson International, Inc.C.H. Robinson: foreign subsidiaries transported Iranian and Cuban goods 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 25 Sep 2026 · Direct link

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22 Nov 2024 United Parcel Service Inc. (UPS)UPS: goodwill of UPS Freight division incorrectly valued – 45 million USD 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 25 Sep 2026 · Direct link

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22 Nov 2024 Jindal Tubular USA LLCPipe mill Jindal Tubular: $442,815 settlement after fatal pipe collapse 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 25 Sep 2026 · Direct link

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19 Nov 2024 Valenti's Bakery LLCNew Jersey bakery: $385,221 because deficiencies remained after finger amputation 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; at the follow-up inspection in May 2024, lockout/tagout procedures were still missing, and in addition exit routes were blocked and fall edges unprotected. Proposed: $385,221 (including failure to abate, 2 wilful and 1 repeat violation).

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 25 Sep 2026 · Direct link

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8 Nov 2024 Invesco Advisers, Inc.Invesco Advisers: 17.5 million USD for inflated ESG integration percentages 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 25 Sep 2026 · Direct link

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

In May 2024, inspectors saw carpenters of the Crystal Lake company working on residential buildings in Elburn at heights of over 6 feet without fall protection three times within one month; training records and forklift certifications were also missing, and rigging equipment was damaged. The company had already been cited in 2022 and 2023. Proposed: $287,465.

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 25 Sep 2026 · Direct link

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22 Oct 2024 Unisys Corp.SEC: $4 million against Unisys for downplaying cyber incidents after SolarWinds 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 25 Sep 2026 · Direct link

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22 Oct 2024 Sahara Dunes Casino, LP (Lake Elsinore Hotel and Casino)FinCEN: 900,000 USD against Lake Elsinore card club over missing reports 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 25 Sep 2026 · Direct link

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16 Oct 2024 RTX Corporation (Raytheon Company)RTX (Raytheon) pays around 391 million USD for bribing a Qatari military official 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 25 Sep 2026 · Direct link

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11 Oct 2024 Moog Inc.Moog: SEC order over bribery of Indian public officials by a subsidiary USABribery of public officials €1.54m

From 2020 to 2022, employees of the Indian subsidiary of the aerospace and defence supplier bribed Indian public officials via agents and distributors, among other things to tailor tenders in Moog's favour; the payments were booked as business expenses. Payment of 504,926 USD in disgorgement, 78,889 USD in interest and a penalty of 1.1 million USD.

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 25 Sep 2026 · Direct link

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10 Oct 2024 The Toronto-Dominion BankFederal Reserve: 123.5 million USD against Toronto-Dominion Bank over AML oversight failure USAInternal controls €113m

The Board of Governors of the Federal Reserve System imposed 123.5 million USD on the Canadian parent company because it neglected risk management and oversight of its US retail business, so that a US subsidiary was used to launder hundreds of millions of dollars. TD must move the AML programme to the US and commission an independent review of the board and management; the sanctions of all authorities involved (DOJ, FinCEN, OCC) add up to around 3.09 billion USD.

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 25 Sep 2026 · Direct link

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1 Oct 2024 Tradition SEF LLCTradition SEF: 875,000 USD – emergency and security tests not brought before the board USACritical infrastructure €789,284

The swap trading platform did not fully inform its board of the results of emergency, technology risk and penetration tests, did not regularly test its business continuity and disaster recovery capabilities and had no adequate risk management. It also failed to produce documents requested during an examination on time despite extensions of deadlines; the Commodity Futures Trading Commission (CFTC) imposed 875,000 USD.

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 25 Sep 2026 · Direct link

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27 Sep 2024 Invitation Homes Inc.Invitation Homes pays 48 million USD in FTC settlement over hidden mandatory fees USAMisleading advertising and pricing €43m

According to the FTC, the largest US landlord of single-family homes advertised monthly rents without mandatory additional fees (for example for smart home technology or utility management), which could add up to more than 1,700 USD a year and only appeared in the lease; further allegations concerned withheld security deposits and evictions. Under the settlement, Invitation Homes is paying 48 million USD for refunds and must include mandatory fees in the advertised price.

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
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 25 Sep 2026 · Direct link

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26 Sep 2024 GQG Partners LLCSEC: GQG Partners pays 500,000 US dollars over NDAs and severance agreement USARetaliation against whistleblowers €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 25 Sep 2026 · Direct link

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16 Sep 2024 COBB Tuning Products, LLCCOBB Tuning: 2.914 million USD for over 81,000 tuners that disable emission controls USA, TXEmissions and permits €2.62m

Since 2015, the Austin-based manufacturer has sold more than 81,000 tuners that deactivate emission controls, as well as 8,400 exhaust pipes with fewer or weaker catalytic converters. The proposed settlement with the U.S. Environmental Protection Agency (EPA) and the U.S. Department of Justice (subject to court approval) provides for a civil penalty of 2,914,000 USD in four instalments, as well as a ban on defeat devices, removal of the ‘delete’ functions, information for dealers and customers, buy-back and destruction of such devices held by employees, and Clean Air Act training for the workforce.

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.

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16 Sep 2024 Fünf Wingstop-Filialgesellschaften in Kern County (Inhaber Clinton Lewis)Wingstop franchisee: 1.7 million USD – overtime evaded by splitting up companies USA, CAWorking time €1.53m

The franchisee ran five Wingstop outlets in Bakersfield as separate companies and deployed employees at several locations on the same day. As a result, they lost out on overtime premiums after eight hours a day or 40 hours a week, premiums for missed meal breaks, paid travel time and the higher minimum wage for larger employers; the settlement of 1.7 million USD concerns around 550 employees.

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
Owner Clinton Lewis personally responsible.

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

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10 Sep 2024 Rudy's Performance Parts, Inc.Rudy's Performance Parts: 10 million USD in criminal and civil penalties for defeat devices USAEmissions and permits €9.07m

From 2014 to 2019, the North Carolina company and its CEO Aaron Rudolf manufactured, sold or installed over 250,000 parts for Ford, GM and Dodge diesel pickups in order to remove emission controls – according to the U.S. Environmental Protection Agency (EPA), producing as much in emissions as more than 11 million additional vehicles. A total of 10 million USD: a civil penalty of 7 million USD in instalments (settlement subject to court approval), a criminal fine of 2.4 million USD against the company together with three years' probation, and a fine of 600,000 USD against the CEO.

What organisations can take from it

Those who run emissions tampering as a business model are liable under civil and criminal law – all the way up to management.

Authority / court
U.S. Environmental Protection Agency / U.S. Department of Justice
Area of law
Environment and sustainability · Emissions and permits
Legal basis
Clean Air Act § 203(a)(3)
Action
Fine
Status of proceedings
unknown
Sector
Automotive
Culpability
intentional
Mitigating circumstances
Payment in instalments because of demonstrated limited ability to pay.
Liability of senior managers
CEO Aaron Rudolf: three years' probation and a fine of 600,000 USD in the criminal proceedings; personally a party to the civil settlement.

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

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

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10 Sep 2024 Deere & CompanyDeere pays 9.9 million USD: Wirtgen Thailand bribed the air force and the highways authority USAGifts, hospitality and benefits €9m

From 2017 to 2020, the acquired subsidiary Wirtgen Thailand provided public officials, including officials of the Royal Thai Air Force and the Department of Highways, with cash, sham consultancy fees, luxurious "factory visit trips", meals and entertainment, and also engaged in commercial bribery. Deere is paying 4,343,401 USD in disgorgement, 1,086,954 USD in interest and a penalty of 4.5 million USD.

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
Liability of senior managers
According to the SEC, senior regional managers who have since left the company were involved (not named).
Published
10 Sep 2024

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

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10 Sep 2024 Keurig Dr Pepper Inc.Keurig Dr Pepper: inaccurate statements on the recyclability of K-Cups in the annual report USADisclosure and reporting obligations €1.36m

In its 2019 and 2020 annual reports, Keurig claimed that tests confirmed the recyclability of the K-Cup 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. Keurig 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 25 Sep 2026 · Direct link

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9 Sep 2024 Acadia Healthcare Company, Inc.SEC: Acadia Healthcare pays 1,386,000 US dollars over waivers of whistleblower awards USARetaliation against whistleblowers €1.26m

Between July 2019 and July 2023, Acadia Healthcare 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, Acadia 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 AppFolio, Inc.SEC: AppFolio pays 692,250 US dollars over waivers of whistleblower awards USARetaliation against whistleblowers €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, AppFolio 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
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 TransUnionSEC: TransUnion pays 312,000 US dollars over waivers of whistleblower awards USARetaliation against whistleblowers €282,532

Between May 2019 and September 2023, TransUnion 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, TransUnion 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 Smart for Life, Inc.SEC: Smart for Life pays 19,500 US dollars over waivers of whistleblower awards USARetaliation against whistleblowers €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, Smart for Life 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
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 Nationwide Planning Associates, Inc.; NPA Asset Management, LLC; Blue Point Strategic Wealth Management, LLCSEC: Nationwide Planning and partners pay 240,000 US dollars over reporting prohibitions USARetaliation against whistleblowers €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 (NPA Asset Management), 70,000 (Nationwide Planning) and 10,000 US dollars (Blue Point).

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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27 Aug 2024 TOTSA TotalEnergies Trading SATotalEnergies trading subsidiary: attempted manipulation of gasoline futures USAMarket abuse and insider dealing €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.

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

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27 Aug 2024 Cleveland Cliffs Burns Harbor LLCCleveland-Cliffs Burns Harbor: EPA settlement over pollutant emissions at steelworks USAEmissions and permits €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.

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18 Jul 2024 DaVita Inc.DaVita: 34.5 million USD – kickbacks for referrals to dialysis centres and pharmacy USACommercial bribery €31.6m

The dialysis group allegedly paid kickbacks to promote referrals to its former pharmacy subsidiary DaVita Rx and granted benefits to nephrologists and vascular surgeons to induce them to send patients to DaVita dialysis centres. DaVita 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.

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1 Jul 2024 Guardian Health Care Inc., Gem City Home Care LLC, Care Connection of Cincinnati LLC und Evolution Health LLCEvolution Health home care providers: 4.5 million USD – kickbacks to senior living facilities and physicians USACommercial bribery €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.

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

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18 Jun 2024 Amazon.com Services, LLCAmazon: 5.9 million USD – undisclosed productivity quotas in two warehouses (Warehouse Quotas Law) USA, CAWorking time €5.51m

Amazon did not inform employees at two warehouses in Moreno Valley and Redlands 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 25 Sep 2026 · Direct link

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12 Jun 2024 Edgewood Residential Facility (Los Angeles)Edgewood Residential: 658,948 USD – care workers up to 24 hours without breaks USA, CAWorking time €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.

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29 May 2024 Innovasis Inc.Innovasis: 12 million USD – kickbacks to spine surgeons USACommercial bribery €11.1m

The Utah manufacturer of spinal implants and two executives – founder and president Brent Felix and former CFO Garth Felix – allegedly paid surgeons kickbacks to induce them to use Innovasis products. Together they paid 12 million USD; 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
Founder/president and former CFO pay personally as parties to the settlement.

Original amount 12,000,000 USD, converted at the ECB reference rate of 29 May 2024.

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22 May 2024 Intercontinental Exchange, Inc. (ICE) und neun Tochtergesellschaften, u. a. New York Stock Exchange LLCIntercontinental Exchange/NYSE: 10 million USD – cyber attack not reported to the SEC USAIncident reporting obligations €9.23m

In April 2021, a third party alerted ICE to a vulnerability in its VPN; ICE 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 the New York Stock Exchange, did not immediately report the incident to the U.S. Securities and Exchange Commission (SEC) as required under Regulation SCI; ICE 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.

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19 Apr 2024 SCG Plastics Co., Ltd.SCG Plastics pays 20 million USD for concealed sales of Iranian polyethylene USABreaches of sanctions and embargoes €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 state-owned National Petrochemical Company. 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.

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18 Mar 2024 Delphia (USA) Inc.SEC ‘AI washing’: Delphia pays 225,000 US dollars for fabricated AI use USAAI systems €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), Delphia 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.

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18 Mar 2024 Global Predictions Inc.SEC ‘AI washing’: Global Predictions pays 175,000 US dollars for AI advertising promises USAAI systems €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 25 Sep 2026 · Direct link

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20 Feb 2024 Kenric Steel LLCSteel fabricator Kenric Steel: $348,683 – deficiencies despite warning from its own consultant USAWorkplace safety and accidents €322,795

Following a complaint, the U.S. Occupational Safety and Health Administration (OSHA) found at the family-run steel fabrication business in Millville (New Jersey), among other things, missing medical evaluations for respirator users, uninspected overhead cranes, incorrectly used welding screens and missing chemical hazard training – even though a safety consultant had identified the deficiencies months earlier. Proposed: $348,683 (4 wilful, 7 serious violations); the company 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.

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8 Feb 2024 La Mina De Oro Inc., KD Distributors, Inc. und Desire Fragrances Inc.La Mina de Oro: 1 million USD – warehouse workers without daily overtime and genuine breaks USA, CAWorking time €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 25 Sep 2026 · Direct link

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16 Jan 2024 J.P. Morgan Securities LLCSEC: J.P. Morgan Securities pays 18 million US dollars over gagging clauses in client settlements USARetaliation against whistleblowers €16.5m

From March 2020 to July 2023, JPMS 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 25 Sep 2026 · Direct link

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