DDTC 2015 Consent Agreements - What's up?

Anyone wondering what happened to 2015 DDTC Consent Agreements?

2015 is the first year since 1996 with no US Department of State Consent Agreements. 

Over the Last 20 years DDTC has averaged just under 2 ½ Consent Agreements per year. The range is 0-5/year. 

So why nothing in 2015?  Is it because: 

-  Industry is doing a better job complying?

-  DDTC is overwhelmed as a result of Export Control Reform?

-  Consent Agreements take many years to work through?

-  There are too many ongoing cases and not enough resources to close them out?

-  Does the number indicate DDTC is shifting gears taking a different approach?

-  There is less emphasis on compliance and enforcement?

-  It’s just an anomaly?

-  Some other reason…?

It’s also worth noting big doesn’t mean better or more compliant.  Over the last 20 years repeat offenders (i.e. those with multiple DDTC settlements) include:  Boeing (4), Raytheon (3), Lockheed Martin (3) and ITT (2).  Those 4 organizations represent 26% of the total number of DDTC 1996-2016 settlements (47).  

Food for Thought/Discussion (pick one):  

-  What’s the impact on you or your organization when there are no DDTC Consent Agreements in a given year?

-  What can be taken away from DDTC Consent Agreements that impacts your organization’s compliance program?

-  What’s the deterrent effect of DDTC Consent Agreements on you, your organization and industry