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Important Takeaways for Exporters from Honeywell’s Consent Agreement with DDTC

On April 27, 2021, Honeywell International, Inc. (“Honeywell”) entered into a consent agreement with the U.S. Department of State Directorate of Defense Trade Controls (“DDTC”) for alleged violations of the Arms Export Control Act (“AECA”) and the International Traffic in Arms Regulations (“ITAR”).  Specifically, Honeywell, a defense contractor based in Charlotte, North Carolina, allegedly exported and retransferred ITAR-controlled technical data without required authorization.

Under the 36-month consent agreement, Honeywell is required to pay a civil penalty of $13 million, though DDTC will suspend $5 million of this amount if Honeywell directs those funds toward DDTC-approved corrective measures to strengthen Honeywell’s compliance program. The consent agreement also requires Honeywell to engage an external “Special Compliance Officer” to oversee the consent agreement for at least 18 months.

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