$42 Million Blackwater Settlement Demonstrates ITAR Enforcement on the Rise

On August 23, 2010, the State Department’s Directorate of Defense Trade Controls (DDTC) published its $42 million Consent Agreement with the private security firm formerly known as Blackwater Worldwide (“Blackwater”; n/k/a Xe Services LLC), settling claims for hundreds of International Traffic in Arms Regulations (ITAR) violations. This highly-anticipated civil settlement followed the State Department’s December 2008 imposition of a “presumption of denial” for all new applications for export licenses or other forms of authorization submitted by Blackwater, with limited exceptions for applications “in direct support of a U.S. Government contract.”