Due to the mandatory nature of the Federal Claims Collection Act (31 U.S.C § 3711) and the absolute duties which they impose upon carriers, the Department regards the penalties under the Act, although recoverable in civil proceedings, as not being merely civil obligations but penal sanctions, and accordingly does not accept compromise settlements of less than the full statutory penalty on each count with costs, to which the government is entitled as a matter of right. See 28 U.S.C. § 1918(a).

[updated January 2020] [cited in JM 9-76.310]