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”).1 Specifically, Honeywell,
a defense contractor based in Charlotte, North Carolina, allegedly
exported and retransferred ITAR-controlled technical data without
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.
The requirements and…