Cosco sat 223 days on a $24,328 FMC fine — and faced a $16.7m penalty threat

Cosco was fined $24,328 in September 2025 after a Federal Maritime Commission reparations proceeding found improper invoicing in its detention and demurrage practices, the fee disputes that have drawn repeated FMC enforcement since the Ocean Shipping Reform Act. The carrier then left the final award unpaid for 223 days. The commission said Cosco 'was aware of its obligations' and that facts brought to its attention indicated the company 'was reminded extensively for months about its non-payment'.

In October 2026 the FMC released a letter stating that Cosco 'appears to have persistently failed to comply with a final reparations order for many months after the date fixed by the commission for payment'. Non-payment of a reparations award carries civil penalties per violation per day — $5,000, or $25,000 where wilful and knowing — which inflation adjustments had lifted to $14,988 and $74,943. Across 223 days of continuing violation, the commission said the total could run between $3.3m and $16.7m if the non-payment is considered wilful.

The letter noted Cosco took 223 days to pay the fine and said the record 'raises the question whether these potential violations of the statute were knowing and wilful'. It came weeks after the FMC lifted the three-year statute of limitations on charge complaints for fees assessed on or after June 16, 2022, keeping carriers exposed to pandemic-era claims.

An FMC letter threatens civil penalties of $3.3m to $16.7m for the 223 days of non-compliance — up to roughly 680 times the original fine.

Cosco treated a final reparations order as optional, staying out of compliance for 223 days while being reminded repeatedly.

The FMC's penalty structure accrues per violation per day, so delay itself multiplies exposure far beyond the original award.

The commission under chair Laura DiBella was signalling it would enforce against foreign carriers, and a slow-paid $24,328 fine was the test case.

Ignoring a small regulatory order is not cheap defiance — per-day penalties accrue on every day of continuing violation, and a $24,000 fine can compound into a seven-figure problem.

The FMC's letter left open whether the 223 days of non-compliance were 'knowing and wilful', which would set the daily rate at the higher $74,943 figure and the total near $16.7m; no final penalty had been announced as of the report. The enforcement posture stood out in contrast to expectations that the new administration would go easy on the industry: the FMC had already extracted more than $22m in repayments from MSC over detention and demurrage practices earlier in 2026, and shippers' lawyers said giving the FMC teeth would encourage smaller shippers to pursue pandemic-era claims.