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  • Raytheon-State Department Settlements Summary

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    John P. Priecko
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    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’s 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’s 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.

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    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’s 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’s 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.

    Copyright:

    Attribution Non-Commercial (BY-NC)
    Download as PDF, TXT or read online from Scribd
    Flag for inappropriate content
    194 views1 page

    Raytheon-State Department Settlements Summary

    Uploaded by

    John P. Priecko
    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’s 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’s 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.

    Copyright:

    Attribution Non-Commercial (BY-NC)
    Download as PDF, TXT or read online from Scribd
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    RAYTHEON - DIRECTORATE OF DEFENSE TRADE CONTROLS (DDTC) SETTLEMENTS COMPARISON/SUMMARY

    (As of 7/6/2013)

    ITEM # 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

    SUMMARY Alleged Violations/Number of Charges Maximum Civil Fine Could Have Been Actual Total Civil Fine Actual Civil Fine per Violation Portion of Civil Fine Suspended Percentage of Actual Fine Suspended Debarment Voluntary Disclosures Directed Disclosures Consent Agreement Term
    GENERAL REMEDIAL MEASURES Measures Incorporated in Business Acquisitions ** Sales or Merger Purchaser or Merging Party Notified in Writing ** Ensure Adequate Resources ** Internal Review ** Status Reports to the DDTC ** Special Compliance Officer (SCO) ** Internal SCO Employee Reporting Mechanism ** Comprehensive Automated Export Compliance System Policies, Procedures and Training of ITAR-Controlled Technical Data (TD) Transferred Electronically Feasibility Study to Maximize Automation of Identification and Tracking of ITAR-Controlled TD ** 5 Year Jurisdiction Review Outside Audits & Audit Plans Legal Department Oversight/Support Written Certification to the DDTC Arrange/Facilitate DDTC Minimum Advance Notice Reviews/Audits Enforce & Adopt Policies & Procedures to Ensure Compliance Compliance Restructuring

    SETTLEMENTS Apr 2013 * Feb 2003 Oct 1999 125 26 11 $62,500,000 $13,000,000 $5,500,000 $8,000,000 $5,000,000 $550,000 $64,000 $192,308 $50,000 $4,000,000 $2,000,000 $50,000 50% 40% 10% No Numerous 2 None Noted 1 Noted 4 Years 3 Years
    X X X X X 2 Years 1 Year 2 Years X X X X

    X 2 Required X X X X 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.
    There are no restrictions on distribution of this document exactly as is with complete citation/attribution. For changes, inputs, suggestions, please contact John Priecko, 703-895-1110 or jpriecko@comcast.net.

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