The Justice Department’s global settlement included a significant False Claims Act resolution, resulting in  a second deferred prosecution agreement (“DPA”) for a three-year term.  A criminal information was filed in the District of Massachusetts charging Raytheon with two counts of major fraud against the United States..  Raytheon agreed to pay $147 million to resolve the criminal allegations. DOJ’s settlement includes a civil resolution of charges...

Raytheon’s comprehensive settlement included FCPA violations and failures to make required disclosures to the Defense Department concerning fees and commissions.  This portion of the settlement was filed in the Eastern District of New York. Raytheon formed a joint venture with a French company.  Its bribery scheme involved a subsidiary of the joint venture, Integrated Defense Systems (“IDS”), which was controlled by Raytheon. Between approximately 2012...

Raytheon’s criminal conduct cut across a variety of topics — it is difficult to imagine but Raytheon’s misconduct occurred in separate parts of the company, involving violations of different laws.  Like most cases, I always question initially: What was Raytheon’s corporate culture? What was the tone set by Raytheon’s leadership? middle management? Raytheon’s weak culture appears to have permeated every aspect of the large conglomerate. ...

Raytheon Company (Raytheon) — a subsidiary of defense contractor, RTX (formerly known as Raytheon Technologies Corporation) — agreed to pay over $950 million to resolve the Justice Department’s investigations into: (i) a major government fraud scheme involving defective pricing on certain government contracts; (ii) violations of the Foreign Corrupt Practices Act (FCPA); and (iii) the Arms Export Control Act (AECA) and its implementing regulations, the International Traffic...

In a significant enforcement action, the U.S. Department of State’s Directorate of Defense Trade Controls (“DDTC”) has charged Oregon-based Precision Castparts Corp. (“PCC”) with multiple violations of the Arms Export Control Act (“AECA”) and the International Traffic in Arms Regulations (“ITAR”). These charges stem from unauthorized exports of sensitive technical data to foreign nationals employed by one of PCC’s subsidiaries, Mold Masters Intl., LLC (“Mold...

Teva Pharmaceuticals USA Inc. (Teva USA) and Teva Neuroscience Inc. (“Teva”) agreed to pay $450 million to resolve two matters that allege Teva violated the Anti-Kickback Statute (AKS) and the False Claims Act (FCA). Teva is the largest generic drug manufacturer in the United States. The settlement resolved two alleged kickback schemes: Medicare Cost-Sharing Scheme and Copay Assistance Foundations First, Teva has agreed to resolve...

On October 9, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued critical guidance aimed at enhancing financial institutions’ compliance with the Export Administration Regulations (“EAR”). This development comes at a time when financial institutions are increasingly becoming focal points in the enforcement of U.S. export controls, particularly given the geopolitical tensions following Russia’s further incursion into Ukraine and the ongoing...