Overview and Summary of DDTC Consent Agreement with AAR International Involving Presidential Airways
By John Priecko*
Below is a detailed summary of the the State Department's Directorate of Defense Trade Controls (DDTC) July 2010 Consent Agreement with AAR International, Inc (AAR). This is a unique successor liability case in several respects. Unlike some previous cases involving alleged violations of the Arms Export Control Act and the International Traffic in Arms Regulations (ITAR) DDTC did not impose any monetary penalty on AAR, the successor in interest to Presidential Airways.
In addition, DDTC did not mention in the Proposed Charging Letter, Consent Agreement or Order that AAR acquired Presidential from Xe Services LLC (formerly Blackwater Worldwide). That omission raises a number of interesting questions and expectations regarding a related settlement involving Xe Services and/or Blackwater for these alleged violations.
Thoroughly reading settlements and monitoring various U.S. Government enforcement and compliance resources on an ongoing basis should be a integral part of any trade compliance professional’s reading and an essential element in any comprehensive Trade Compliance Program. One-page summaries like these will help get the word out and more quickly and allow readers to digest and compare individual cases.
*Mr. Priecko is the President of Trade Compliance Solutions, a network of experienced compliance-related professionals. He is a trade compliance veteran with more than 15 years of experience. He can be reached at 703-895-1110 or email@example.com.
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