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Civil Monetary Penalties

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The US Treasury Department’s Office of Foreign Assets Control (“OFAC”), the US State Department’s Directorate of Defense Trade Control (“DDTC”), and the US Commerce Department’s Bureau of Industry and Security (“BIS”) have announced increases in the maximum civil monetary penalties (“CMPs”) under the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015 (“2015 Act”). This statute requires the agencies to make such adjustments annually by January 15 of each year.  These newly adjusted CMPs may be imposed for violations of OFAC sanctions regulations, the International Traffic in Arms Regulations, and the Export Administration Regulations (“EAR”).