Toyota is already facing a fine of more than $16 million for failing to promptly notify the government about defective gas pedals.
The Transportation Department told Toyota in a letter this week that accelerator pedals involved in the recall exhibited two separate defects that may require two separate remedies.
The government also said if there weren't a cap of about $16.4 million on fines, Toyota could have faced civil penalties of $13.8 billion. That's because the government could fine the company $6,000 for each of the 2.3 million vehicles under recall.
Toyota has recalled more than 8 million vehicles worldwide.