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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 | 5 min read | 08.21.26

FTC Proposes Enforcement Policy Statement on Personalized Pricing: What Businesses Need to Know

On August 19, 2026, the Federal Trade Commission (FTC) announced a proposed Enforcement Policy Statement on personalized pricing — the practice of companies using consumers’ personal data to set individualized prices, discounts, coupons, or other incentives. The proposed statement, which is open for public comment for 30 days following publication in the Federal Register, marks a major step up in the FTC’s focus on data-driven pricing strategies and puts businesses across industries on notice that undisclosed or inadequately disclosed personalized pricing will not be tolerated. Importantly, while the proposed statement is not a binding legal requirement and does not create new legal obligations, it serves as an enforcement warning that the FTC is prepared to use its existing enforcement authority under Section 5 of the FTC Act (Section 5) and is also a potential harbinger of rulemaking. Businesses that engage in — or are considering — personalized pricing should carefully assess their disclosure practices and data collection procedures against the standards articulated in this statement....