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FROM THE DEFENSE DESK / SNAP VIOLATIONS
6 MAR 2026 · UPDATED 20 AUG 2026 · 1 MIN READ · BY TODD A. SPODEK
THE BRIEF · FILED UNDER: SNAP VIOLATIONS
DOCKET NO. 615 · THE DEFENSE DESK

USDA SNAP CMP - Civil Money Penalty.

Learn how the USDA imposes Civil Money Penalties (CMP) in lieu of permanent disqualification for SNAP trafficking violations. Discover eligibility criteria, documentation requirements, calculation methods, and payment deadlines for CMPs under federal SNAP regulations. Ensure compliance and protect your business from disqualification.

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Overview of Civil Money Penalties

The USDA may impose a civil money penalty, known as a CMP, in lieu of permanent disqualification for trafficking. The CMP must be requested within 10 calendar days of receiving a charge letter from the USDA. The USDA does not give extensions for time to request a CMP in lieu of permanent disqualification.

Eligibility for Civil Money Penalty

In order to be eligible for a CMP, you must meet the four criteria established in Section 278.6(i) of the SNAP Regulations.

The Four Eligibility Criteria

  • Criterion 1 - The firm had an effective compliance policy in place
  • Criterion 2 - The compliance policy was in effect PRIOR to the violations
  • Criterion 3 - The firm had developed and set up effective personnel training
  • Criterion 4 - The firm ownership was not aware of, did not approve of, and did not benefit from trafficking

Documentation and Evidence Requirements

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