As expected, OFAC waited till the last second to update its civil monetary penalty statutory maximums. Adjustments were due by July under the Federal Civil Monetary Penalty Inflation Adjustment Act Enhancement Act of 2015, which compelled agencies who had ignored the Federal Civil Monetary Penalty Inflation Adjustment Act of 1990’s requirement to adjust penalties every 3 years.
Here are the old figures and the new, by statute:
|Statute||Old Maximum||New Maximum|
|Trading with the Enemy Act (TWEA)||$65,000||$83,864|
|International Emergency Economic Powers Act (IEEPA)||$250,000 or twice the transaction amount||$284,582 or twice the transaction amount|
|Foreign Narcotics Kingpin Designation Act (FNKDA)||$1,075,000||$1,414,020|
|Antiterrorism and Effective Death Penalty Act (AEDPA)||$55,000 or twice the required retained amount||$75,122 or twice the required retained amount|
|Clean Diamond Trade Act (CDTA)||$10,000||$12,856|