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Defense Trade Violation Penalties Increased

Thursday, March 21, 2019
Sandler, Travis & Rosenberg Trade Report

The Department of State is increasing the maximum amounts of the civil monetary penalties it assesses for violations of the following provisions of the Arms Export Control Act. These updated amounts will apply to all penalties assessed on or after March 19 regardless of when the actual violation occurred.

- $1,163,217 (previously $1,134,602) for each violation of 22 USC 2778 (control of exports and imports of defense articles and services)

- $845,764 (previously $824,959) or five times the amount of the prohibited payment, whichever is greater, for each violation of 22 USC 2779a (prohibition on incentive payments to satisfy an offset agreement for defense articles or services with a foreign country)

- $1,006,699 (previously $981,935) for each violation of 22 USC 2780 (prohibition on transactions with, including defense exports to, countries supporting acts of international terrorism)

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