Boeing Settles Widespread Compliance Failures on Installment Plan

The Boeing Company will make three $9 million payments to the government to settle a pattern of material violations of export control law, including unauthorized exports of USML controlled technical data, unauthorized exports of defense articles, and Unauthorized Exports Resulting from Fabricated Permanent Export Licenses.

The company agreed to name a Designated Official to head a review of the firms compliance and to spend at least $24 million on consultants, auditors and training.

Among items agreed upon, Boeing agreed to conduct a review of its AECA and ITAR compliance resources, enhanced and strengthened compliance procedures, implement an Automated Export Compliance System, c full classification review, and engage two differnt oustide consultants to conduct sequential audits..

Multiple Violations

The Boeing Company settled allegations that it violated the International Traffic in Arms Regulations (ITAR) in connection with:

• unauthorized exports and retransfers of technical data to foreign-person employees and contractors; unauthorized exports to the People's Republic of China, a proscribed country; and
• violations of license terms, conditions, and provisos of DDTC authorizations.
• The ITAR violations are derived from 24 voluntary disclosures that Respondent submitted to DDTC between December 2017 and September 2022 including
• Unauthorized Exports to Foreign-Person Employees and Contractors 
• Unauthorized Exports to FPEs in a Proscribed Country (China)
• Unauthorized Exports to FPEs and Contractors in 18 Other Countries 
• Unauthorized Exports and Retransfers to FPEs and Contractors in Australia and India 
• Unauthorized Exports, Reexports, Retransfers, and Temporary Imports of Defense Articles, including Technical Data 
• Unauthorized Exports Resulting from Fabricated Permanent Export Licenses 
• Unauthorized Exports and Retransfers of Technical Data Resulting from Jurisdiction and Classification Issues 
• Unauthorized Exports, Retransfers, and Temporary Imports of Defense Articles, and
• Violation of Terms, Conditions, and Provisos of DDTC Authorizations 

Exposed files were controlled under multiple USML categories, including IV(i), VIII(i), IX(e)(1), XI(d), XII(f), XIII(l), XIX(g), and involved multiple U.S. Department of Defense (DoD) platforms, including. the F-18, F-15, F-22, E-3 Airborne Warning and Control System, AH-64 Apache, AGM-84E Standoff Land Attack Missile, and AGM-131 Short Range Attack Missile II, and Air Force One.

• [Charging Letter]. [Agreement].  [Order]