Lessons From The L3Harris Technologies Consent Agreement With DDTC

On September 19, 2019, the U.S. Directorate of Defense Trade Controls ("DDTC") entered into a consent agreement with L3Harris Technologies, Inc. ("L3Harris") for alleged violations of the Arms Export Control Act ("AECA") and the International Traffic in Arms Regulations ("ITAR"). L3Harris, an aerospace and defense technology company, allegedly committed violations that involved the unauthorized export of defense articles and technical data, as well as a failure to provide accurate and complete reporting and violations of licenses.¹

The L3Harris consent agreement with DDTC provides five valuable takeaways for all defense exporters:

1. Voluntary Disclosures Must Be Voluntary

While L3Harris described many of its alleged violations in voluntary self-disclosures ("VSD") submitted to DDTC, the government did not find every VSD to be a mitigating factor. DDTC began its investigation by sending L3Harris a directed disclosure after DDTC was informed by the Defense