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 | $97,178 | $99,703 |
| 21 U.S.C. 1901-1908 – Foreign Narcotics Kingpin Designation Act | $1,829,177 | $1,876,699 |
| 19 U.S.C. 3901-3913 – Clean Diamond Trade Act | $16,630 | $17,062 |
Crowell & Moring, LLP continues to monitor export control and sanctions developments and their potential impact on customers and businesses going forward.