Dept of State Concludes $13 Million Settlement of Alleged Export Violations by Honeywell

May 3, 2021 – The U.S. Department of State has concluded an administrative settlement with Honeywell International, Inc. (Honeywell) of Charlotte, North Carolina, to resolve alleged violations of the Arms Export Control Act (AECA), 22 U.S.C. § 2751 et seq., and the International Traffic in Arms Regulations (ITAR), 22 C.F.R. Parts 120-130. The Department of State and Honeywell have reached this settlement following an extensive compliance review by the Office of Defense Trade Controls Compliance in the Department’s Bureau of Political-Military Affairs.

The Department of State and Honeywell have reached an agreement pursuant to ITAR § 128.11 to address alleged unauthorized exports and retransfers of ITAR-controlled technical data that contained engineering prints showing dimensions, geometries, and layouts for manufacturing castings and finished parts for multiple aircraft, gas turbine engines, and military electronics to and/or within Canada, Ireland, Mexico, the People’s Republic of China, and Taiwan.

The settlement demonstrates the Department’s role in strengthening U.S. industry by protecting U.S.-origin defense articles, including technical data, from unauthorized exports. The settlement also highlights the importance of obtaining appropriate authorization from the Department for exporting controlled articles.

Under the terms of the 36-month Consent Agreement, Honeywell will pay a civil penalty of $13 million. The Department has agreed to suspend $5 million of this amount on the condition that the funds will be used for Department-approved Consent Agreement remedial compliance measures to strengthen Honeywell’s compliance program. In addition, for an initial period of at least 18 months, an external Special Compliance Officer will be engaged by Honeywell to oversee the Consent Agreement, which will also require the company to conduct one external audit of its compliance program during the Agreement term as well as implement additional compliance measures.

Honeywell voluntarily disclosed to the Department the alleged violations that are resolved under this settlement. Honeywell also acknowledged the serious nature of the alleged violations, cooperated with the Department’s review, and instituted a number of compliance program improvements during the course of the Department’s review. For these reasons, the Department has determined that it is not appropriate to administratively debar Honeywell at this time.