Three Raytheon Settlements Provide Insight into Evolving Perspectives on Compliance and Enforcement at the Directorate of Defense Trade Controls (DDTC

If you only read the most recent Raytheon-DDTC settlement documents you do not get a complete picture of their compliance culture, history over the last 15 years, how the State Department used to handle cases and how they approach them now, especially in the area of mandated compliance measures.

If you want some valuable additional insight and telling trend information, check out the one page Raytheon-DDTC Settlements Summary/Comparison at http://www.scribd.com/doc/152123272/Raytheon-DDTC-Settlements-Summary
or http://www.slideshare.net/jpriecko/raytheon-ddtc-settlements-summary-070613.

It provides an interesting side-by-side comparison of the April 2013, February 2003 and October 1999 Raytheon settlements with the DDTC. A few significant differences are worth noting. Is there one thing in particular that seems most obvious?

What do you attribute the differences over time to? What do you think are the most important takeaways when considering all three of the Raytheon-DDTC settlements?

April 30, 2013, Raytheon Settlement Summary - Important Lessons Learned

A concise one-page summary of the April 30, 2013, US Department of State settlement with the Raytheon Company is now available online at: http://www.slideshare.net/jpriecko/raytheon-043013-settlement-summary-060613

or at http://www.scribd.com/doc/151713277/April-2013-Raytheon-Settlement-Summary. 

It is a bite-size tool in a template format summarizing material facts from the Proposed Charging Letter, Consent Agreement and Order.  For more on the lessons learned and key takeaways, read the narrative introductory text on either of the above sites.

Keeping You Informed on Unique West Coast Outreach, Education and Training Opportunities

You are invited to attend two guaranteed, high-quality, cost-effective, hands-on, practical application and case study focused workshops on December 4^th in Los Angeles (LA) and December 6^th in San Diego.  Both programs are hosted by the US Commercial Service and District Export Councils along with other local, state, national and international sponsors and partners.   

With a confirmed second Obama administration and ongoing Export Control Reform it’s even more important than ever before for trade compliance and export control professionals to attend and contribute.  In particular, with the migration of thousands of articles from the US Munitions List to the Commerce Control List these are timely opportunities.  You and your organization need to be represented.

If you haven't already, it’s time to register.  For an LA area agenda, more details and registration go to: http://export.gov/california/losangeleswest/tradeevents/workshop/.  For San Diego go to: http://export.gov/california/sandiego/index.asp

For abbreviated presenter bios go to: http://www.scribd.com/doc/109922667/WORKSHOPS-FOR-EXPORT-COMPLIANCE-PROFESSIONALS-Abbreviated-Presenter-Bios.

If you have questions about the LA area workshops, please contact: Delia Valdivia, 310-235-7203 or delia.valdivia@trade.gov.  For San Diego it’s Julie Osman, 858-467-7037 or julie.osman@trade.gov.

What happened to the United Technologies Corporation (UTC) and many of its subsidiaries?

For a concise one-page overview of the State Department case go to:  http://www.scribd.com/doc/113572181/UTC-Department-of-State-Settlement-Summary.

The summary consolidates material from the US Department of State’s Proposed Charging Letter, Consent Agreement and Order.  It is a much more concise and consistent summary in a format that is particularly useful for C-level executives and trade compliance professional’s education/training at all levels. 

Thoroughly reading settlements including monitoring various US Government enforcement and compliance resources including websites should be an integral part of any trade compliance professional’s reading and an essential element in any comprehensive Trade Compliance Program.

One-page summaries like these help get the word out in a more bite-size way and allow readers to more quickly digest and compare individual cases.

To better appreciate the two 2012 UTC enforcement actions (one criminal and one civil); you must carefully read the entire settlement package on the DDTC website at http://www.pmddtc.state.gov/compliance/consent_agreements/UTC.html.  Details on the DOJ case are included in a Press Release at http://www.justice.gov/opa/pr/2012/June/12-nsd-824.html.

CONSIDER:  What impact and implications are there regarding these cases that apply to you and your organization?

 

If you are not yet up-to-speed on what happened and the lessons learned, it is past time to get clued-in.

In Case You Missed It: Office of Management (OMB) Action Impacts Progress on Export Control Reform (ECR)

The OMB has slowed down publication of Federal Register notices.  This is standard policy at the end of any administration leading up to an election to avoid last minute rulemaking.  Thus, aggressive plans in various ECR related areas including the first transfers of US Munitions List defense articles to the Commerce Control List are in a somewhat fuzzy gray area. 

You have likely already figured this out, but the outcome of the elections can have a profound impact on ECR efforts on many fronts.

December 2012 Los Angeles and San Diego Area WORKSHOPS FOR EXPORT COMPLIANCE PROFESSIONALS

Join the U.S. Department of Commerce, U.S. & Foreign Commercial Service along with other local, national and international partners in Los Angeles, California, Tuesday, December 4th, and San Diego, California, Thursday, December 6th, for engaging and interactive workshops addressing the Export Administration Regulations (EAR), International Traffic in Arms Regulations (ITAR) and related trade compliance requirements, responsibilities, roles, problems, exposure, liability and risk that organizations and individuals face.

A big focus will be on the migration of defense articles and services from the US Munitions List to the Commerce Control List and the impact and implications on you and your organization. Are you ready?

These low cost and high quality hands-on, practical application, case study based workshops will much better prepare, educate and train you and your organization to deal with and be ready for a wide-range of real world situations, consequences and other adverse actions in the currently invigorated enforcement environment. The morning session focuses on Jurisdiction and Classification and the afternoon on Audits and Assessments. Both days end with a Networking Reception.

For a Los Angeles area agenda, more details and online registration go to: http://export.gov/california/losangeleswest/tradeevents/workshop/. For San Diego: http://export.gov/california/sandiego/index.asp.

For a Los Angeles flyer go to: http://www.scribd.com/doc/109923731/Los-Angeles-Area-WORKSHOPS-FOR-EXPORT-COMPLIANCE-PROFESSIONALS-Flyer. For San Diego: http://www.scribd.com/doc/109923943/San-Diego-Area-WORKSHOPS-FOR-EXPORT-COMPLIANCE-PROFESSIONALS-Flyer.

For abbreviated bios on all the presenters go to: http://www.scribd.com/doc/109922667/WORKSHOPS-FOR-EXPORT-COMPLIANCE-PROFESSIONALS-Abbreviated-Presenter-Bios.

If you have questions about the Los Angeles area workshops, please contact: Delia Valdivia, 310-235-7203, delia.valdivia@trade.gov. For San Diego, please contact Julie Osman, 858-467-7037,julie.osman@trade.gov.

ROCKY MOUNTAIN EXPORT COMPLIANCE AND ENFORCEMENT FORUM - Don't Miss it!

REMINDER: You are invited and encouraged to attend the 2nd Annual Arizona Export Compliance Summit, September 12-13, 2012, hosted by the Arizona District Export Council (ADEC) and US Comm... (More) You are invited and encouraged to attend the engaging and interactive one-day Rocky Mountain Export Compliance and Enforcement Forum, October 17, hosted by the US Commercial Service, Denver Export Assistance Center and a variety of other local, national and international Sponsors and Partners.

It is a lower-cost, higher-quality, unique, practical application-oriented, hands-on education and training program including a seminar and networking reception sponsored by the law firm of Holland and Hart LLP, 555 Seventeenth Street, Suite 3200, Denver CO 80202-3979.
 
Among other things, the Forum will provide you the latest on Export Control Reform, its impact, implications and what you should be doing to stay ahead of the dramatic changes.
For a one-page flyer with agenda details and more information go to http://www.scribd.com/doc/101878040/Rocky-Mountain-Export-Compliance-Forum-Flyer.

For abbreviated bios on all the presenters go to http://www.scribd.com/doc/108495877/Rocky-Mountain-Export-Compliance-and-Enforcement-Forum-Abbreviated-Presenter-Bios.

Discounts for ICPA members and others are available. For convenient online registration go to https://www.regonline.com/rockymountainforum.

If you have questions, contact Katie Cloyd, 303-295-8188; kmcloyd@hollandhart.com.