Episode 345 -- Raytheon Pays $950 Million to Resolve Fraud, FCPA, ITAR and False Claims Act Violations
On April 10, the Trump administration announced, through an executive order (EO), a new initiative to reform the defense sales system, with the goal of improving the speed and accountability of the system....more
This is the final in our 2025 Year in Preview series examining important trends in white collar law and investigations in the coming year. Throughout 2024, enforcement of international trade laws continued to gather pace...more
In October 2024, the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) announced settlements with Raytheon Company, a division of multinational defense contractor RTX, over defective pricing and...more
The U.S. Department of State's Directorate of Defense Trade Controls (DDTC) has finalized significant changes to the registration fees under International Traffic in Arms Regulations (ITAR). The Arms Export Control Act...more
What happens when a major defense contractor faces scrutiny for ethics and compliance violations? In this episode of Corruption, Crime, and Compliance, Michael Volkov dives into the high-stakes world of corporate...more
Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more
Raytheon Company (Raytheon) — a subsidiary of defense contractor, RTX (formerly known as Raytheon Technologies Corporation) — agreed to pay over $950 million to resolve the Justice Department’s investigations into: (i) a...more
In a significant enforcement action, the U.S. Department of State’s Directorate of Defense Trade Controls (“DDTC”) has charged Oregon-based Precision Castparts Corp. (“PCC”) with multiple violations of the Arms Export Control...more
August was another robust month in international trade that further signifies the need for corporations to invest in effective compliance programs. For starters, the DOJ unveiled a new program that incentivizes corporate...more
On July 9, 2024, District Judge David Hale in Kentucky denied motions to dismiss and motions to suppress filed by four defendants against a criminal case involving ITAR charges for illegal exports of sensitive,...more
On February 24, the two-year anniversary of Russia’s invasion of Ukraine, the Biden administration issued hundreds of new Russia-related export controls and sanctions. The Office of Foreign Assets Control (OFAC) and the...more
As many of you are aware, with some minor exceptions, the United States bifurcates export controls responsibility between the Department of State, which administers the International Traffic in Arms Regulations (the “ITAR”),...more
The discovery of actual or potential International Traffic in Arms Regulations (“ITAR”) violations presents the question of whether to disclose the conduct to the Department of State Directorate of Defense Trade Controls...more
On July 19, 2023, Rep. Michael McCaul (R-TX), chair of the House of Representatives Foreign Affairs Committee, introduced a bill to ease trade restrictions among parties to the AUKUS agreement—a trilateral security...more
United States international trade regulatory agencies have updated voluntary self-disclosure (“VSD”) policies and guidance in an effort to incentivize private sector companies and individuals to self-report violations of U.S....more
In early June 2023, legislation was proposed in the U.S. Congress to amend the U.S. Arms Export Control Act to provide an exemption for licensing of defense items for export to the United Kingdom (U.K.)....more
May saw several Russia-related enforcement and other actions. The Department of Justice (DOJ) identified and charged three foreign nationals with violating export control laws as they attempted to circumvent Russian...more
WHAT: In a prior alert, we discussed a report from the Aerospace Industries Association (AIA), National Defense Industrial Association (NDIA), and Professional Services Council (PSC) presented to a U.S. Department of Defense...more
The U.S. Department of Justice (“DOJ”) on May 16 announced criminal charges and arrests that highlight risks for companies from U.S. and non-U.S. networks and individuals that seek to unlawfully divert U.S. goods, services,...more
Compliance Program Guidelines - On December 5, 2022, the U.S. Department of State Directorate of Defense Trade Controls (“DDTC”) issued new Compliance Program Guidelines (“the Guidelines”) intended to provide an overview...more
On December 5, 2022, the Department of State, Directorate of Defense Trade Controls (“DDTC”) issued new Compliance Program Guidelines, “intended to provide an overview of an effective compliance program and an introduction to...more
Importer Pays $3.25M Settlement in FCA Case A California importer paid $3.25 million (Law360 subscription required to view) to settle a whistleblower suit brought by a former employee of its overseas supplier under the False...more
Joe Compliance has an export control issue involving definition of some of the terms being used. Joe goes to the website of the Directorate of Defense Trade Controls (pmddtc.state.gov) and clicks on “Review the ITAR.” He...more
Regulatory compliance is critical for any business involved in the export of defense related commodities. Violations under the International Traffic in Arms Regulation (ITAR) or the Export Administration Regulations (EAR) can...more
At a sanctions conference held in Washington D.C. on May 5, government officials, practitioners and corporations highlighted the government’s broadening focus on anti-corruption enforcement, across more traditionally siloed...more