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DOJ Makes Significant Inflation Adjustment to Civil Monetary Penalties

Client Alert | less than 1 min read | 07.01.16

DOJ published an interim final rule on June 30, 2016, adjusting civil monetary penalties for inflation, that nearly doubles the prior penalty amounts under the Civil False Claims Act from the existing range of $5,500 - $11,000 to a new range of $10,781 - $21,563. The increased amounts, however, apply only to civil penalties assessed after August 1, 2016, for violations that occurred after November 2, 2015, while the penalty amounts for penalties assessed or for violations that occurred before these respective dates remain unchanged.

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Client Alert | 8 min read | 10.01.25

BIS Issues “Affiliates Rule” to Dramatically Expand Applicability of Entity and Military End-User Lists

On September 29, 2025, the U.S. Department of Commerce Bureau of Industry and Security (BIS) announced a sweeping Interim Final Rule (IFR), (the “Affiliates Rule”) expanding which entities qualify as Entity List or Military End-User entities, thereby subjecting those entities to elevated export control restrictions under the Export Administration Regulations (EAR). U.S. export restrictions applicable to entities on the Entity List, Military End-User (MEU) List, and Specially Designated Nationals and Blocked Persons (SDN List) now apply to foreign affiliates that are, in the aggregate, owned 50% or more by one or more of the aforementioned entities. An entity that becomes subject to these restrictions because of its ownership structure will be subject to the most restrictive controls that attach to any of its parent entities, regardless of ownership stakes....