Does the ACRB intend to change enforcement policy? Will penalties increase?
A. The ACRB was not designed to increase or decrease penalties. The primary goal of the ACRB is to assist the Assistant Secretary in promoting legal and administrative best practices in EE enforcement policy and to advise the Assistant Secretary in a timely manner at important stages of administrative cases. Because enforcement policies, including penalties sought, are subject to continual review, it is possible that from time to time past practices will be evaluated and, if necessary, adjusted to reflect more accurately BIS program and enforcement goals. In part, the ACRB is intended to help the Assistant Secretary ensure that any change in enforcement policy by BIS management is implemented in an orderly fashion and based on principles of fairness and consistency.