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ARTICLE · 18 JANUARY 2024

OFAC Updates Civil Monetary Penalties

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Last week, OFAC announced it is increasing its maximum amount of the civil monetary penalties (CMP) that may be assessed under relevant OFAC regulations by implementing the Federal Civil Penalties Inflation Adjustment Act of 1990 for 2024.

United StatesInternational Law

Last week, OFAC announced it is increasing its maximum amount of the civil monetary penalties (CMP) that may be assessed under relevant OFAC regulations by implementing the Federal Civil Penalties Inflation Adjustment Act of 1990 for 2024. These increases adjust for inflation and have occurred nine times since 2015. The changes to the CMPs are as follows:

Statute

2023 Maximum Civil Monetary Penalty

2024 Maximum Civil Monetary Penalty

Trading With the Enemy Act (TWEA)

$105,083

$108,489

International Emergency Economic Powers Act (IEEPA)

$356,579 (or twice the transaction value (whichever is greater)

$368,136 (or twice the transaction value (whichever is greater)

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