Largest Fines for Violations of Trade Sanctions: Why Businesses Need Sanctions Audits

As of March 2026, more than 20,000 individuals and legal entities have been included in international sanctions lists due to connections with Russia. Of these, approximately 9,000 are Russian individuals and companies, while the remainder are intermediaries from China, Iran, Mexico, and other countries.

For companies operating in global markets, violating export controls or engaging with sanctioned suppliers represents a tangible risk of incurring multi-million-dollar fines or facing criminal investigations that can severely damage business reputation.

TriTrace Investigations highlights five of the largest cases.

5. 2024 — Aiotec GmbH (Germany): $9,7 million fine

In 2013–2014, a polypropylene production plant in Australia with a capacity of up to 150,000 tons per year was dismantled. The former owners decided to sell the plant equipment.

A U.S. company acted as a broker in the transaction and resold the plant to the German industrial equipment supplier Aiotec GmbH for $9,7 million. The contract explicitly prohibited the resale of the equipment to countries subject to U.S. sanctions.

According to the U.S. Department of the Treasury, while negotiating delivery of the plant to Turkey (on behalf of a U.S. client), Aiotec’s management simultaneously discussed selling the equipment to the Iranian company Petro-Iranian Downstream Industries Development Co. Senior management was aware of the transaction, and attempts were made to conceal the involvement of the Iranian entity through falsified documentation.

As a result, the seller was fined an amount equal to the value of the transaction — $9,7 million.

4. 2025 — Cadence Design Systems (USA): $140 million

Cadence Design Systems develops software and hardware used in the design of integrated circuits and processors.

One of the customers of Cadence’s Chinese subsidiary was the National University of Defense Technology (NUDT) of the People’s Liberation Army of China. In 2015, the university was added to the U.S. Department of Commerce Entity List, prohibiting the sale of U.S. technologies without a special license. U.S. authorities believe that NUDT uses American technology to simulate nuclear explosions and military operations.

According to court documents, starting in 2015, Cadence and its Chinese subsidiary sold controlled U.S. technologies through a proxy entity affiliated with the university — Central South CAD Center.

At least 59 shipments were made over five years. Following the investigation, the company agreed to plead guilty and pay criminal penalties exceeding $140 million.

3. 2026 — Applied Materials Inc. (USA): $252 million

Applied Materials produces equipment and software for semiconductor manufacturing.

Through its South Korean subsidiary, the company supplied products to Semiconductor Manufacturing International Corporation (SMIC), China’s largest contract chip manufacturer. Since 2020, SMIC has been included in the Entity List and cannot acquire such technologies without authorization from U.S. regulators.

The value of equipment and technology exported in violation of sanctions amounted to approximately $126 million. Under a settlement agreement, Applied Materials agreed to pay a $252 million fine — the second-largest penalty ever imposed by the U.S. Department of Commerce’s Bureau of Industry and Security.

2. 2023 — Seagate Technology (USA): $300 million

In August 2020, the U.S. Bureau of Industry and Security added Huawei to the Entity List.

Of the three U.S. hard drive manufacturers that had worked with Huawei, only Seagate Technology chose to continue supplies. Between 2020 and 2021, the company sold more than 7 million hard drives to the Chinese manufacturer, totaling over $1 billion.

This resulted in a record fine in the history of the Bureau of Industry and Security — $300 million. According to the regulator, the penalty exceeded by more than two times the profit Seagate earned from its sales to Huawei.

1. 2023 — British American Tobacco (UK): $629 million

Between 2007 and 2017, the multinational tobacco company British American Tobacco sold cigarettes to North Korea. Although the company formally claimed to have exited the market, supplies continued through an intermediary structure in Singapore.

Over ten years, $415 million in revenue from illegal cigarette sales passed through this Singapore-based shell company.

U.S. regulators imposed a $629 million fine on British American Tobacco. In addition, U.S. authorities filed criminal charges in absentia against participants in the scheme — a North Korean banker and two Chinese intermediaries.

Mitigating the risk of criminal prosecution for sanctions violations requires robust supply chain oversight and comprehensive sanctions audits.

TriTrace Investigations conducts due diligence on exporters and suppliers for connections with Russia. More information about these and other services is available in the relevant section of our website.