Loading…
Loading…
Under the Federal Civil Penalties Inflation Adjustment Act of 1990 (28 U.S.C. 2461 note), as strengthened by the 2015 Improvements Act, all federal agencies must publish annual inflation-adjusted CMP amounts no later than January 15 of each calendar year. OFAC calculates the adjustment using the October-to-October change in the Consumer Price Index for All Urban Consumers (CPI-U) published by the Bureau of Labor Statistics; the 1.03241 multiplier for 2024 reflects the October 2022 → October 2023 interval.
The five statutory authorities whose CMP ceilings OFAC adjusts annually are:
authority underlying most OFAC sanctions programs (Russia, Iran, China military-end-user, Venezuela, etc.)
embargo and Korean War–era programs
trafficking-related sanctions
sanctions; penalty is the greater of the adjusted amount or twice the amount in a retained transaction
The adjusted amounts are codified in 31 CFR § 501.701 (OFAC penalties and findings of violation) and replace the prior-year figures with immediate effect.
| Authority | Statutory baseline | Prior ceiling (2023) | 2024 adjusted ceiling |
|---|---|---|---|
| IEEPA (50 U.S.C. 1705) | Greater of $250,000 or 2× transaction | $356,579 | $368,136 |
| TWEA (50 U.S.C. 5) | $65,000 per violation | $105,083 | $108,489 |
| FNKDA (21 U.S.C. 1906) | $1,075,000 per violation | $1,771,754 | $1,829,177 |
| AEDPA (8 U.S.C. 219) | Greater of $55,000 or 2× retained amount | $94,127 | $97,178 |
| CDTA (19 U.S.C. 3907) | $10,000 per violation | $16,108 | $16,630 |
January 12, 2024 onward; compliance teams at financial institutions, fintech platforms, investment advisers, and trading firms calibrate risk-adjusted reserve provisions to these figures when stress-testing sanctions exposures.
greater) is the operative reference for the vast majority of OFAC settlements and administrative determinations, as virtually all sanctions programs authorised after 1977 derive from IEEPA authority.
SDNTK designations) affecting financial flows in Latin American, Southeast Asian, and West African jurisdictions.
1 retained unless Congress amends the underlying statutory baselines, which would constitute a materially new policy action.
codified at 31 CFR Parts 501 and 536) will consolidate the inflation-adjustment schedule and the penalty framework in a unified rulemaking for 2025 onward.