FCC v. AT&T · ¶36

First, several features of the statute demonstrate that forfeiture orders do not obligate payment. The statute nowhere gives the Commission the authority to execute on a forfeiture order; it cannot, for example, seize the carriers' assets or obtain liens on their property. See Federal Elec tion Comm'n v. Ted Cruz for Senate, 596 U. S. 289, 301 (2022) (agency “literally has no power to act . . . unless and until . . . authorize[d] . . . by statute” (internal quotation marks omitted)). A recipient of a forfeiture order incurs no penalties for nonpayment, and interest does not accrue on the sum. In re Amendment, 19 FCC Rcd. 6540, 6542, n. 16 (2004); FCC Directive, FCC INST 1157.5, Forfeiture Tracking, Collections and Follow-up Systems 1–3 (May 22, 2023). And under §504(c) of the Act, the Commission cannot hold “the existence of a notice of liability or an order of forfeiture” against a…

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