As of January 15, 2025, Commerce, Energy, State, and Treasury have each published their annual increase in civil monetary penalties for violations of U.S. export controls and sanctions regulations to account for inflation.  Below is a summary of the increases for calendar year 2025.

U.S. Department of Commerce
EAR Section2024 Maximum PenaltiesNew 2025 Maximum Penalties
15 CFR § 764.3(1)(i) – Export Controls Act of 2018$364,992$374,474
15 CFR § 764.3(1)(i) – International Emergency Economic Powers Act$368,136$377,700
U.S. Department of Energy
Part 810 Section2024 Maximum PenaltiesNew 2025 Maximum Penalties
10 CFR § 810.15(c)$124,732$127,973
U.S. Department of State
ITAR Section2024 Maximum PenaltiesNew 2025 Maximum Penalties
22 CFR § 127.10(a)(1)(i)The greater of $1,238,892 or the amount that is twice the value of the transaction that is the basis of the violation with respect to which the penalty is imposed.The greater of $1,271,078 or the amount that is twice the value of the transaction that is the basis of the violation with respect to which the penalty is imposed.
22 CFR § 127.10(a)(1)(ii)$1,028,988, or five times the amount of the prohibited payment, whichever is greater.$1,055,721, or five times the amount of the prohibited payment, whichever is greater.
22 CFR § 127.10(a)(1)(iii)$1,224,787$1,256,607
U.S. Department of Treasury
Statute2024 Maximum PenaltiesNew 2025 Maximum Penalties
50 U.S.C. 4301-4341 – Trading With the Enemy Act$108,489$111,308
50 U.S.C. 1701-1706 – International Emergency Economic Powers Act$368,136$377,700
18 U.S.C. 2339B – Antiterrorism and Effective Death Penalty Act$97,178$99,703
21 U.S.C. 1901-1908 – Foreign Narcotics Kingpin Designation Act$1,829,177$1,876,699
19 U.S.C. 3901-3913 – Clean Diamond Trade Act$16,630$17,062

Crowell & Moring, LLP continues to monitor export control and sanctions developments and their potential impact on customers and businesses going forward.

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Photo of Jana del-Cerro Jana del-Cerro

Maria Alejandra (Jana) del-Cerro is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade and Government Contracts groups. She advises clients with respect to the U.S. regulation of outbound trade, including U.S. export controls. Jana

Maria Alejandra (Jana) del-Cerro is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade and Government Contracts groups. She advises clients with respect to the U.S. regulation of outbound trade, including U.S. export controls. Jana works with clients across a broad range of industries, from traditional aerospace and defense manufacturers and multi-national software companies, to start-ups in the technology sector, and she regularly represents them before the Departments of State, Commerce, and Treasury in responding to government inquiries, conducting internal reviews, and in compliance investigations and voluntary disclosures.

Photo of Dilan Wickrema Dilan Wickrema

Dilan Wickrema advises clients with respect to U.S. export controls, economic sanctions, the foreign military sales process, the Committee on Foreign Investment in the United States (CFIUS), and related investigations. Dilan leverages his experience from his various roles at the intersection of international

Dilan Wickrema advises clients with respect to U.S. export controls, economic sanctions, the foreign military sales process, the Committee on Foreign Investment in the United States (CFIUS), and related investigations. Dilan leverages his experience from his various roles at the intersection of international trade and national security in the federal government to ensure clients meet their cross-border transaction goals while complying with the applicable laws and regulations. Previously, Dilan served in the Directorate of Defense Trade Controls (DDTC), the Bureau of Industry and Security, and the International Trade Administration.

Photo of Edward Goetz Edward Goetz

Edward Goetz is the Director for International Trade Services in Crowell & Moring’s Washington, D.C. office. Edward leads the firm’s international trade analysts providing practice support to the International Trade Group in the areas of customs regulations, trade remedies, trade policy, export control…

Edward Goetz is the Director for International Trade Services in Crowell & Moring’s Washington, D.C. office. Edward leads the firm’s international trade analysts providing practice support to the International Trade Group in the areas of customs regulations, trade remedies, trade policy, export control, economic sanctions, anti-money laundering (AML), anti-corruption/anti-bribery, and antiboycott. He has extensive government experience providing information and interpretive guidance on the International Traffic in Arms Regulations (ITAR) concerning the export of defense articles, defense services, and related technical data. He also assists attorneys with matters involving the Export Administration Regulations (EAR), economic sanctions, AML, anti-corruption/anti-bribery, and trade remedies.