Even if you export defense articles, technical data, or defense services pursuant to contracts with the U.S. government or military, don't assume that you are free from the usual export control requirements that apply to those items, or that the U.S. Government will "look the other way" regarding other aspects of
your exporting operations. Making such a mistake may prove extremely costly.
That message was delivered emphatically by the Department of State, Directorate of Defense Trade Controls ("DDTC" through a $42 million settlement with private security contractor Xe Services, LLC ("Xe Services"), formerly known as Blackwater, for numerous alleged violations of the International Traffic in Arms Regulations ("ITAR"). Several important lessons can be taken from the settlement Xe Services.
reached with DDTC.
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