Settlements

ST-54
BAE Systems plc
BAE Systems plc
United States
Department of State
Czech Republic, Hungary, Saudi Arabia, Chile, Indonesia, South Africa and many others (unnamed)
2010
05/16
United Kingdom
Legal Person
Civil
Consent Agreement
Civil Penalty
$79,000,000.00
$0
$0
$79,000,000
$0
Art.16, Art.23, Art.26
Art. 1, Art. 2, Art. 7, Art. 8
Violations of Arms Export Control Act and International Traffic in Arms Regulations (Failure to Register as a Broker, Failure to Obtain Written Approval for Brokering, Failure to File Annual Broker Reports, Causing Unauthorized Brokering, Failure to Disclose Payments, Failure to Maintain Records)
Violations of Arms Export Control Act and International Traffic in Arms Regulations (Failure to Register as a Broker, Failure to Obtain Written Approval for Brokering, Failure to File Annual Broker Reports, Causing Unauthorized Brokering, Failure to Disclose Payments, Failure to Maintain Records)
Yes
According to the US Department of State Consent Agreement, on May 16, 2011, BAE Systems plc entered into an agreement with the State Department "to settle 2,591 violations of the Arms Control Export Act and International Traffic in Arms Regulations in connection with the unauthorized brokering of U.S. defense articles and services, failure to register as a broker, failure to file annual broker reports, causing unauthorized brokering, failure to report the payment of fees or commissions, and failure to maintain records involving ITAR-controlled transactions. As part of the Consent Agreement, the company was assessed $79 million in civil penalties, with $10 million possibly suspended upon implementation of remedial measures. (Source: US Department of State, BAE Systems plc, Consent Agreement signed May 16, 2011.) The Statement Department's May 2011 Proposed Charging Letter included a Summary of Investigation, which noted misconduct related to activities in more than a dozen jurisdictions. (Source: US Department of State, BAE Systems plc, Proposed Charging Letter, May [ ] 2011.)