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:

Statute2023 Maximum Civil Monetary Penalty2024 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)
Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA)$94,127 (or twice the transaction value (whichever is greater)$97,178 or twice the amount  which a financial institution was required to retain (whichever is greater)
Foreign Narcotics Kingpin Designation Act (FNKDA)$1,771,754$1,829,177
Clean Diamond Trade Act (CDTA)$16,108$16,630

The Department of Commerce and The Department of State recently made similar increases to their CMPs.

Crowell & Moring, LLP will continue to monitor U.S. trade regulations for updates.