Trade Law Daily is a Warren News publication.

DDTC Updates Redline Document for New Penalty Amounts

The State Department’s Directorate of Defense Trade Controls this week updated its redline document to reflect a recent revision to its maximum monetary penalty amounts. The document uses colors to highlight text that has been deleted, moved and revised in the International Traffic in Arms Regulations.

Sign up for a free preview to unlock the rest of this article

Timely, relevant coverage of court proceedings and agency rulings involving tariffs, classification, valuation, origin and antidumping and countervailing duties. Each day, Trade Law Daily subscribers receive a daily headline email, in-depth PDF edition and access to all relevant documents via our trade law source document library and website.

DDTC said its new maximum penalty for violations of Section 38 of the Arms Export Control Act, which was amended by the FY 2023 National Defense Authorization Act, is now either $1.2 million or twice the value of the transaction at the heart of the violation -- whichever is greater. That new maximum penalty amount will apply only to penalties assessed for violations that occurred on or after Dec. 27. Other revised penalty amounts, which were adjusted for inflation earlier this week ​​(see 2301100016), apply only to penalties assessed on or after Jan. 11.