The State Department has announced a 36-month consent agreement (available here) under which a company will pay a $36 million civil penalty to resolve 104 violations of the Arms Export Control Act and the International Traffic in Arms Regulations. These include the company’s unauthorized exports of technical data to multiple countries; violations of terms, conditions, and provisos of several Directorate of Defense Trade Controls authorizations involving various countries; and unauthorized exports of defense articles, including technical data, designated as significant military equipment.
State notes that the company voluntarily disclosed all but one of the alleged violations, fully cooperated with the department’s review, and has implemented numerous improvements to its ITAR compliance program since the conduct at issue.
State has agreed to suspend $18 million of the penalty on the condition that those funds are used for the consent agreement’s measures to strengthen the company’s compliance program. In addition, for an initial period of at least 24 months, the company will engage an external special compliance officer to oversee the consent agreement, which will also require at least one external audit of its ITAR compliance program and implementation of additional compliance measures.
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