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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
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 Section
2024 Maximum Penalties
New 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 Section
2024 Maximum Penalties
New 2025 Maximum Penalties
10 CFR § 810.15(c)
$124,732
$127,973
U.S. Department of State
ITAR Section
2024 Maximum Penalties
New 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
Statute
2024 Maximum Penalties
New 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
Crowell & Moring, LLP continues to monitor export control
and sanctions developments and their potential impact on customers
and businesses going forward.
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
