Pursuant to the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015 (2015 Act), Congress required agencies to make yearly adjustments to their civil monetary penalties (CMPs) as well as a one-time “catch up” adjustment to their CMPs to account for inflation. On June 8, 2016, the Department of State announced that it is enacting “catch-up” adjustments to the maximum amounts of the civil monetary penalties (CMPs) it issues. Regardless of when the violation occurred, these new penalty amounts will only apply to penalties assessed after August 1, 2016.

Penalties under the Arms Export Control Act (AECA) (22 U.S.C. §§ 2778(e), 2779(a), 2780(k)) are assessed by the Directorate of Defense Trade Controls (DDTC). Each of the penalty provisions of the AECA provides the CMP cannot exceed $500,000. But, pursuant to the adjustments, the maximum CMP amounts will be increased to: $1,094,010 per violation of 22 U.S.C. § 2778(e); $795,445 per violation of 22 U.S.C. § 2779(a); and $946,805 per violation of 22 U.S.C. § 2780(k).  You can read more here.