after August 1).3 The 2015 Act, however, does not retrospectively change any previously assessed or enforced penalties.4 Also, penalties under the Internal Revenue Code and the Tariff Act are exempt from the 2015 Act's inflation adjustment.5Below are some of the notable increases in federal civil fines under the 2015 Act: Agency Relevant LawUnderlying Violations Current Penalty Adjusted Penalty Increase (%) FTC6Federal Trade Commission Act, 15 U.S.C. 45(l)Violations of cease and desist orders issued under Section 5(b) of the FTC Act (e.g., breach of terms under FTC consent order) $16,000 $40,000 150%FTC Act, 15 U.S.C. 45(m)(1)Unfair or deceptive acts or practice in violation of Section 5(m)(1) of the FTC Act $16,000 $40,000 150%Hart-Scott-Rodino (HSR) Improvements Act, 15 U.S.C. 18a(g)(1) Violations of premerger reporting and waiting requirements under the HSR Act (e.g., failure to file or late filing of premerger notification) $16,000 (per day) $40,000 (per day) 150%Clayton Act, 15 U.S.C. 21(l)Violations of cease and desist orders issued under Section 11(b) of the Clayton Act $8,500 $21,250 150% DOJ7False Claims Act (FCA), 31 U.S.C. 3729(a)Violations of FCA (e.g., healthcare fraud, housing and mortgage fraud, and false claims for payment under government contracts) $5,500 – $11,000 $10,781 – $21,563 96%Financial Institutions Reform, Recovery, and Enforcement Act (FIRREA), 12 U.S.C. 1833a(b)(1)Violations of FIRREA (e.g., financial fraud “affecting a federally insured financial institution”) Max. $1,100,000 Max.