RTX Monitor “Expected To Be In Place” 1.5 Years After Settlement
In October 2024, Raytheon (which changed its name to RTX in 2023) resolved a DOJ/SEC enforcement action with various prongs: Foreign Corrupt Practices Act, False Claims Act, Arms Export Control Act and the International Traffic in Arms Regulations.
The net $361.2 million FCPA enforcement action (net $259.7 million DOJ FCPA enforcement action and a net $101.5 million SEC FCPA enforcement action) concerned a bribery scheme involving a high-level official at the Qatar Emiri Air Force to obtain or retain business.
A Spectrum Of Third Party Compliance
Like many FCPA enforcement actions, the recent RTX (Raytheon) matter largely focused on a problematic third party used to facilitate the alleged bribery schemes.
The DOJ and SEC resolution documents make for an interesting read and tell a story across a wide spectrum of third party compliance from due diligence, to oversight and supervision, to payment.
The story demonstrates that when it comes to third parties, several things can be “true” (based on DOJ/SEC allegations findings) all at the same time.
It can be “true” that culpable employees knowingly circumvented existing third party compliance policies and procedures in place and it can also be “true” that others within the company were seemingly indifferent to the activities of a third party.
Issues To Consider From The RTX Enforcement Action
This prior post went in-depth into the recent RTX (Raytheon) FCPA enforcement action regarding bribery schemes in Qatar.
The net $361.2 FCPA enforcement action involved a net $259.7 million DOJ FCPA enforcement action and a net $101.5 million SEC FCPA enforcement action.
This post highlights additional issues to consider.
Timeline
As RTX previously disclosed:
RTX Resolves Net $361 Million FCPA Enforcement Action
Raytheon (which changed its name to RTX in 2003) has been under Foreign Corrupt Practices Act (and related) scrutiny for several years.
As highlighted in this prior post, in late July 2024 the company disclosed that it would be resolving (among other things) an FCPA matter and that settlement would include a DOJ deferred prosecution agreement (with an independent compliance monitor requirement) and an SEC order.
Today, the DOJ and SEC announced resolution of the matter. Resolution involved various prongs including the False Claims Act, the Arms Export Control Act (AECA) and the International Traffic in Arms Regulations.
RTX Discloses Upcoming FCPA (And Related) Settlement
Raytheon (which changed its name to RTX in 2003) has been under Foreign Corrupt Practices Act scrutiny for several years.
RTX recently disclosed an upcoming Foreign Corrupt Practices Act (and related) settlement to include a DOJ deferred prosecution agreement (with an independent compliance monitor requirement) and an SEC order.
The disclosure states: