Last week, the US Sentencing Commission approved a package of proposed amendments "intended to promote fairer and more consistent application" of the federal sentencing guidelines. At the center of those changes is a long-awaited inflation adjustment to the guidelines’ loss table which is likely to lower sentencing exposure in many financial-crime cases. Although the Commission considered a number of ambitious reforms during the public comment period, the final package reflects a more incremental approach, leaving several proposals for future consideration. Unless Congress intervenes, the amendments will take effect on November 1, 2026.
Inflation Adjustment
The most consequential, and practically significant, change is the inflation adjustment to the monetary thresholds in the guidelines’ loss table, which drives offense levels in financial-crime cases. This is the first such adjustment in more than a decade, and it meaningfully recalibrates how economic harm is translated into