US Treasury, State, and Commerce - Monetary Penalty Increases Last Two Years

The Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015 (the "Act") required federal agencies to adjust their maximum allowable civil monetary penalties ("CMPs") annually.  The initial "catch-up" adjustments occurred in 2016; and now the first annual adjustments have been finalized by the US Department of Commerce's Bureau of Industry and Security ("BIS"), the US Treasury Department's Office of Foreign Assets Control ("OFAC"), and the US Department of State's Directorate of Defense Trade Control ("DDTC").  The chart below provides a reference for the original, 2016 "catch-up", and 2017 annual adjustment penalty amounts.