raytheon-ddtc settlements summary
DESCRIPTION
If you only read the most recent April 30, 2013, Raytheon-Directorate of Defense Trade Controls (DDTC) settlement documents you did not get a complete picture of their compliance culture, history over the last 15 years, how the DDTC used to handle cases and how they approach them now. That is especially so in the area and evolution of mandated compliance measures. This one-page side-by-side comparison of the April 2013, February 2003 and October 1999 settlements with the DDTC provide additional valuable insight and telling trend information. There is a significant amount of material to be considered and factored in to your export control/trade compliance program. One thing in particular should be very obvious to you.TRANSCRIPT
RAYTHEON - DIRECTORATE OF DEFENSE TRADE CONTROLS (DDTC) SETTLEMENTS COMPARISON/SUMMARY
(As of 7/6/2013)
ITEM #
SUMMARY
SETTLEMENTS Apr 2013 * Feb 2003 Oct 1999
1 Alleged Violations/Number of Charges 125 26 11 2 Maximum Civil Fine Could Have Been $62,500,000 $13,000,000 $5,500,000 3 Actual Total Civil Fine $8,000,000 $5,000,000 $550,000 4 Actual Civil Fine per Violation $64,000 $192,308 $50,000 5 Portion of Civil Fine Suspended $4,000,000 $2,000,000 $50,000 6 Percentage of Actual Fine Suspended 50% 40% 10% 7 Debarment No 8 Voluntary Disclosures Numerous
None Noted
2 9 Directed Disclosures 1 Noted
10 Consent Agreement Term 4 Years 3 Years
GENERAL REMEDIAL MEASURES
11 Measures Incorporated in Business Acquisitions
X
12 ** Sales or Merger Purchaser or Merging Party Notified in Writing
X
13 ** Ensure Adequate Resources X
14 ** Internal Review X
15 ** Status Reports to the DDTC X
16 ** Special Compliance Officer (SCO) 2 Years 1 Year
17 ** Internal SCO 2 Years
18 Employee Reporting Mechanism X
19 ** Comprehensive Automated Export Compliance System
X
20 Policies, Procedures and Training of ITAR-Controlled Technical Data (TD) Transferred Electronically
X
21 Feasibility Study to Maximize Automation of Identification and Tracking of ITAR-Controlled TD
X
22 ** 5 Year Jurisdiction Review X
23 Outside Audits & Audit Plans 2 Required
24 Legal Department Oversight/Support X
25 Written Certification to the DDTC X
26 Arrange/Facilitate DDTC Minimum Advance Notice Reviews/Audits
X
27 Enforce & Adopt Policies & Procedures to Ensure Compliance
X
28 Compliance Restructuring X
NOTES: * This is a Global settlement with another $20,000,000 paid to the US Customs Service. ** These measures specifically apply to all operating divisions, subsidiaries and business units.
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For changes, inputs, suggestions, please contact John Priecko, 703-895-1110 or [email protected].