As with licensing agreements, there are many things related to temporary licences that need to be constantly checked in the context of licensing management: like Meggitt, Aeroflex and Raytheon have learned this year in an expensive way when it comes to export compliance, the devil is often in the details. These three companies entered into follow-up agreements with the Department of Foreign Affairs for violation of the ITAR and were fined millions of dollars ($8 million to $25 million). While some of these dealt with important issues, such as the misclassification of articles submitted to ITAR, most of the infringements involved breaches in the proper management of agreements or licences. A few examples: Raytheon Recently entered into an approval agreement with the U.S. Department of State`s DDTC, which rejected allegations that it violated the Arms Export Control Act and the International Traffic in Arms Regulations (ITAR) by failing to properly manage licensing agreements and temporary export and import licenses. First, we should mention that, although Raytheon was the subject of the approval agreement, the problems caused by this action apply to many other companies. Half of the fine is suspended on the condition that Raytheon use the money for state-approved measures to meet funds, including enhanced training and supervision. The company also agreed to hire an independent special representative for compliance, who oversaw the four-year approval order. The U.S. State Department said it reached the agreement with Massachusetts-based Raytheon after a thorough review showed that the company`s “numerous violations showed a recurring weakness across the company” in maintaining effective compliance controls. Let`s look at the chords. Most ITAR licensing agreements are valid for 10 years. Much can happen during this period, for example: the U.S.
State Department has obtained an administrative agreement with raytheon Company (Raytheon) after a comprehensive implementation review to correct hundreds of civil violations of the Arms Export Control Act (AECA) and the International Traffic in Arms Regulations (ITAR).