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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. FinCEN calculates the adjustment using the October-to-October change in the Consumer Price Index for All Urban Consumers (CPI-U) published by BLS; the multiplier for 2024 reflects the October 2022 → October 2023 interval.
The adjusted amounts replace the statutory baseline figures. They do not cap total penalty exposure for continuing violations (per-day penalties accumulate without ceiling). The rule is a final rule effective on publication, issued without notice-and-comment under the "good cause" exemption because the adjustment formula is non-discretionary.
| U.S. Code | Penalty description | Statutory baseline | 2024 adjusted max |
|---|---|---|---|
| 12 U.S.C. 1829b(j) | Recordkeeping violations for funds transfers | $10,000 | $25,597 |
| 12 U.S.C. 1955 | Willful or grossly negligent recordkeeping | $10,000 | $25,597 |
| 31 U.S.C. 5318(k)(3)(C) | Failure to terminate correspondent relationship with foreign bank | $10,000 | $17,315 |
| 31 U.S.C. 5321(a)(1) | General civil penalty for willful BSA violations | $25,000–$100,000 | $69,733–$278,937 |
| 31 U.S.C. 5321(a)(5)(B)(i) | Foreign financial agency transaction — non-willful | $10,000 | $16,117 |
| 31 U.S.C. 5321(a)(5)(C)(i)(I) | Foreign financial agency transaction — willful | $100,000 | $161,166 |
| 31 U.S.C. 5321(a)(6)(A) | Negligent violation by financial institution or non-financial trade or business | $500 | $1,394 |
| 31 U.S.C. 5321(a)(6)(B) | Pattern of negligent activity | $50,000 | $108,489 |
| 31 U.S.C. 5321(a)(7) | Due diligence, correspondent accounts, and special measures violations | $1,000,000 | $1,731,383 |
| 31 U.S.C. 5330(e) | Failure to register as money transmitting business | $5,000 | $10,289 |
| 31 U.S.C. 5336(h)(3)(A)(i) | Beneficial ownership information (BOI) reporting violation | $500 | $591 |
| 31 U.S.C. 5336(h)(3)(B)(i) | Unauthorized disclosure or use of BOI | $500 | $591 |
financial institutions, MSBs, and investment advisers calibrate risk-adjusted compliance budgets to these figures.
by the Corporate Transparency Act; separately, CFPB enforcement of FinCEN BOI rules via its own CMP schedule operates under a different adjustment table.
figure for BSA enforcement settlements and consent orders negotiated with FinCEN in 2024.
amends underlying statutory baselines, which would constitute a materially new policy action.
enforcement framework or continue adjusting them alongside the BSA penalty table.
for willful non-filers following the CTA litigation resolution.