USDOS Concludes $36 Million Settlement Resolving Export Violations By General Electric Company.

Washington DC; April 2026: The U.S. Department of State has concluded an administrative settlement with General Electric Company (GE Aerospace) to resolve 116 violations of the:

• Arms Export Control Act (AECA), 22 U.S.C. § 2751 et seq.,
• International Traffic in Arms Regulations (ITAR), 22 C.F.R. parts 120-130.

The Department of State and GE Aerospace reached this settlement following an extensive compliance review by the Office of Defence Trade Controls Compliance in the Department’s Bureau of Political-Military Affairs.

The administrative settlement between the Department of State and GE Aerospace, concluded pursuant to International Traffic in Arms Regulations (ITAR) § 128.11, addresses multiple categories of ITAR violations, including GE Aerospace’s unauthorised exports of technical data to the People’s Republic of China; violations of terms, conditions, and provisos of several Directorate of Defence Trade Controls authorisations involving various countries; unauthorised exports of defence articles to two countries; and failure to report material changes to its ITAR registration.

GE Aerospace voluntarily disclosed all the alleged violations, a substantial portion of which predate 2023. GE Aerospace also fully cooperated with the Department’s review of this matter and has implemented numerous improvements to its ITAR compliance program since the conduct at issue.

Under the terms of the 36-month Consent Agreement, GE Aerospace will pay a civil penalty of $36 million. The Department has agreed to suspend $18 million of this amount on the condition that the funds will be used for the Department-approved Consent Agreement’s remedial compliance measures to strengthen GE Aerospace’s compliance program. In addition, for an initial period of at least 24 months, GE Aerospace will engage an external Special Compliance Officer to oversee the Consent Agreement, which will also require at least one external audit of its ITAR compliance program and implementation of additional compliance measures.

This settlement demonstrates the Department’s role in furthering the national security and foreign policy of the United States by controlling the export of defence articles. The settlement also highlights the importance of exporting defence articles pursuant only to appropriate authorisation from the Department.

BACKGROUND –

In 2024, General Electric Company completed its split into three independent businesses focused on aerospace, healthcare, and energy. General Electric Company retained the aerospace business currently operating as GE Aerospace and conducts business under the GE Aerospace name. GE Aerospace designs, manufactures, and exports a variety of ITAR-controlled defence articles, including military aircraft engines, related components, integrated systems, and provides aftermarket services for overseas corporate and government customers in the aerospace and defence markets.

VIOLATIONS –

The ITAR violations levelled against the respondent (GE Aerospace) are derived from 12 voluntary disclosures Respondent submitted to DDTC in accordance with 22 C.F.R. 127.12 between August 2019 and December 2024.

Due in part to the large number of violations over an extended period of time, the Department provides a summary of the violations, which fall into four broad categories:

1) unauthorised exports of technical data to the People’s Republic of China (PRC);

2) failure to manage DDTC authorisations properly;

3) unauthorised exports of defence articles; and

4) failure to report material changes to Respondent’s DDTC registration.

The violations demonstrate a failure to maintain effective ITAR compliance practices and require further remedial action across Respondent’s operating units and subsidiaries.

I. Unauthorised Exports of Technical Data to the People Republic Of China:

In three separate voluntary disclosures, Respondent disclosed that it exported without authorisation technical data to the PRC, a proscribed destination under 22 C.F.R. 126.1(d)(1). The technical data at issue is described in USML Categories VIII(i) and XIX(g) and is related to military aircraft engines for

multiple U.S. Department of War platforms, including the F/A-18, U-2, F-16, and F-15 aircraft. These violations resulted from specific deficiencies in and employees failing to follow Respondent’s policies and procedures regarding the export of technical data.

Respondent disclosed that in April 2018 an employee on temporary travel hand-carried from the United States to the PRC a company-issued laptop with at least 45 files containing USML Categories VIII(i) and XIX(g) technical data, including design data related to electrical power generation for the F-35 aircraft and the F414 military aircraft engine. After giving a presentation at a PRC university, the employee left the laptop in the custody of university officials for approximately 90 minutes while touring a campus facility. Respondent also acknowledged that the same employee previously “made other trips to China carrying the same [company-issued] device and therefore some of the same data.”

Respondent further disclosed that in January 2021, another employee exported without authorisation one drawing containing USML Category XIX(g) technical data via the company’s data transfer system to a PRC-based supplier as part of a request for quotation. The drawing depicted a high-pressure turbine stator seal specially designed for use on the F118 military aircraft engine. Although the data transfer system identified the drawing as ITAR-controlled, the employee improperly selected a Department of Commerce license to complete an internal export authorisation certification and sent the drawing to the PRC. Respondent’s investigation into the unauthorised export revealed that the employee who exported the drawing to the PRC “did not understand the distinction between ITAR and Export Administration Regulations (EAR) controlled data”.

Respondent additionally disclosed that on three occasions between April and August 2023, it exported to the PRC without authorisation compact discs that stored an Interactive Electronic Technical Manual (IETM) containing USML Category XIX(g) technical data related to maintenance and repair processes for the F110 military aircraft engine. Respondent transhipped the articles through the PRC, en route to Singapore. Respondent did not configure its account with its freight forwarder to solicit information about whether the shipments containing the IETMs were ITAR-controlled and thus prohibited from transiting proscribed destinations. As a result, the freight forwarder shipped the packages containing the IETMs to Singapore via the PRC. Respondent acknowledged gaps in its export procedures that did not specifically address shipping routing. Harm to U.S. National Security

The U.S. Government reviewed copies of the technical data referenced in these three voluntary disclosures and determined that certain unauthorised exports to the PRC harmed U.S. national security. Specifically, the U.S. Government determined that the unauthorised export of the USML Category XIX(g) drawing of the high-pressure turbine stator seal provided the PRC information related to the F118 military aircraft engine. The unauthorised exports of the technical data detailed in the other two disclosures could have provided the PRC with insights into the design, manufacture, configuration, and testing of components of other military aircraft engines, including the F110 and F414 models.

II. Mismanagement of DDTC Authorisations:

Respondent submitted six voluntary disclosures from 2022-2024 involving numerous violations that demonstrated deficiencies in its ability to manage DDTC authorisations properly. The violations described in these six disclosures are detailed below.

In 2023, Respondent reported that it had identified potential violations related to its execution of multiple authorisation management requirements, including DDTC provisos. In response, Respondent conducted a review of all active authorisations from the previous five years and submitted a voluntary

disclosure revealing numerous authorisation management violations discovered over the course of its review. As part of that review, Respondent disclosed that the violations resulted primarily from “its lack of sufficient policies, procedures, and controls” to manage authorisations in compliance with the ITAR.

Additionally, Respondent reported that, as of October 2023, it found multiple operating procedures related to authorisation management had not been updated for more than 10 years and therefore did not incorporate updated requirements contained in published revisions to the ITAR and other guidance from DDTC.

Respondent submitted a voluntary disclosure in 2022 reporting that between January 2021 and February 2022, it caused retransfers without authorisation of USML Category VIII(h)(16) Stores Management Processors (SMP) to the United Kingdom Ministry of Defence (UK MOD). While the UK MOD was a party and signatory to a technical assistance agreement (TAA) supporting the development

and repair of SMPs, it was not listed on the TAA as an end-user. Respondent received non-conforming SMPs from an approved foreign signatory, repaired them, and then caused its foreign signatory to retransfer them without authorisation to the UK MOD. Respondent acknowledged that its “misunderstanding regarding the role of the UK MOD in the [TAA]” resulted in these violations.

Between July 2019 and August 2024, Japanese parties to one of Respondent’s manufacturing license agreements (MLA) retransferred without authorisation USML Category XIX(f)(2) designated as SME and XIX(f)(3) defence articles and XIX(g) technical data related to the F110 military aircraft engine to unauthorised sublicensees in Japan. Despite Respondent’s responsibilities as the authorisation holder to ensure that, pursuant to 22 C.F.R.127.1(c), its foreign signatories operate in compliance with the ITAR, Respondent relied on incomplete information provided by its supplier and subsequently identified weaknesses in its process for verifying sublicensee information. In this case, foreign parties to the MLA incorrectly determined that their sub-tier suppliers did not require authorisation from DDTC to receive defence articles. As a result, the foreign signatory did not include them in the information it furnished to Respondent in support of the authorisation request.

Respondent also disclosed in June 2024 that sometime in 2021 a Swedish party to a TAA reexported without authorisation USML Category XIX(g) technical data involving the maintenance, overhaul, and modification for the RM12 military aircraft engine to a South African entity that was not listed on the

authorisation. Respondent did not identify the unauthorised South African entity as an additional party or sublicensee to the TAA when it submitted its application to DDTC due to its Swedish signatory’s assessment that the entity was a component of the South African National Defence Force, which was an authorised party to the TAA.

In addition, between May 2021 and March 2024, Respondent exported without authorisation USML Category XIX(g) technical data that was outside the scope authorised under the TAA related to the manufacture of electrical wiring harnesses and leads for the F119, F135, and F414 military aircraft engines to suppliers in Mexico. Respondent cited its “lack of clear internal guidance regarding the build-to-print restriction on technical data”, which limited the TAA’s scope.

Respondent further disclosed multiple violations related to an MLA authorising the manufacture of USML Category XIX(f)(3) turbine blades for the T901-GE-900 gas turbine engine. Specifically, Respondent utilised the 22 C.F.R. 126.5 license exemption to export USML Category XIX(f)(3) blade castings to a sublicensee in Canada on 30 occasions between September 2020 and April 2024 in

violation of a DDTC proviso that required Respondent to obtain separate licenses for the export of hardware in furtherance of the agreement. Due to its misuse of the exemption, Respondent also failed to decrement the exports against the MLA’s authorised value. The Canadian sublicensee in turn reexported without authorisation the blade castings to Respondent’s indirect wholly-owned subsidiary

in Poland on multiple occasions between March 2021 and April 2024.

Additionally, Respondent furnished defence services without authorisation between October 2020 and November 2024 when it engaged in technical discussions with the Canadian sublicensee. The MLA authorised neither the furnishing of defence services to the Canadian sublicensee nor the export of

technical data directly from GE Aerospace to the Canadian sublicensee. In its root cause analysis, Respondent cited a “lack of a streamlined process for [International Trade Compliance (ITC)] personnel to fully assess applicable facts prior to providing export guidance”, which contributed to inaccurate guidance from ITC personnel.

In connection with its voluntary disclosure related to improper authorisation management, Respondent disclosed multiple violations of DDTC provisos limiting the scope of its agreements. The violations included: failure to remove a foreign party from its TAA in contravention of a proviso directing Respondent to remove the party for foreign policy reasons; failure to remove certain defence services

from a TAA involving military aircraft engines; and failure to adhere to a proviso limiting the export of material and finish specifications to Norway, Poland, Spain, and the UK.

Respondent also violated provisos requiring submission of additional information prior to execution of agreements. On one occasion, Respondent failed to provide an exhaustive list of aircraft platforms in a TAA as DDTC instructed in a proviso to its amendment approval. Regarding another TAA amendment,

Respondent failed to revise the TAA to include mandatory language from 22 C.F.R. 124.8(a)(5), which requires DDTC authorisation for the transfer to foreign persons of technical data and defence services pursuant to an agreement.

Further, Respondent violated on eight occasions provisos to licenses requiring purchase orders prior to engaging in offshore procurement of defence articles. The provisions contained in 22 C.F.R. 124.13(d) require applicants to submit copies of purchase orders that accord with the requirements of 22 C.F.R.

124.13(c) to DDTC after issuance of an offshore procurement license. Offshore procurement arrangements are not effective until applicants meet these conditions.

Respondent disclosed other violations of terms and conditions of authorisations, including export of defence articles in excess of the authorised quantity on export licenses; failure to include key provisions on a Non-Disclosure Agreement signed by a foreign-person employee, as required for DDTC approval of a permanent export license; and failure to execute amendments to agreements, use authorised freight forwarders listed on licenses, and include correct party information on various authorisations.

Respondent’s review further identified failure to comply with generally applicable ITAR provisions that relate to authorisations. For example, Respondent failed on multiple occasions to submit to DDTC required information regarding a TAA authorising technical support for the F414-GE-39E military aircraft engine to the Swedish Armed Forces, resulting in a failure to notify the transaction to Congress, as required under 22 C.F.R. 123.15.

III. Unauthorised Exports of Defence Articles:

Respondent submitted a voluntary disclosure regarding the unauthorised export to Sweden of one SME USML Category XIX(f)(2) combustion liner designed for the F404-400 military aircraft engine in June 2021. Respondent had a license to export a different XIX(f)(2) combustion liner to Sweden and attached commercial documentation for the combustion liner intended for export to Sweden to the shipping box containing the F404-400 combustion liner, resulting in its unauthorised export to Sweden rather than to the intended recipient in the United States.

Respondent submitted a separate voluntary disclosure involving the unauthorised temporary export to Israel of 15 USML Category VIII(h)(1) machined chassis specially designed for the F-35 aircraft between July and September of 2020. A GE Aerospace employee improperly applied a Department of Commerce Export Control Classification Number (ECCN) to the commercial invoice for the ITAR-controlled machined chassis. Because the employee selected an ECCN that did not require a Department of Commerce export license to Israel,

Respondent’s internal procedures did not require ITC to review the transaction prior to export.

IV. Failure to Report Material Changes to its DDTC Registration:

Respondent repeatedly failed to report material changes to its Statement of Registration, as required under 22 C.F.R. 122.4. Respondent disclosed to DTCC that it “found weaknesses in the company’s procedures that define requirements for managing its ITAR Registration”.

In sum, the violations described above demonstrate that Respondent failed to establish and adequately staff an ITAR compliance program commensurate with its global presence and extensive participation in ITAR-controlled activities.

ORDER –

FIRST, that Respondent shall pay in fines and in remedial compliance measures a civil penalty of thirty-six million dollars ($36,000,000), as stipulated below, in complete settlement of the civil violations arising from facts Respondent disclosed to the Department in its disclosures assigned the DTCC Case Numbers identified in paragraph 27 of the Consent Agreement and, also, summarised in the Department’s Proposed Charging Letter.

SECOND, six million dollars ($6,000,000) of this civil penalty is to be paid to the Department within ten (10) days of signing of the Order; six million dollars ($6,000,000) is to be paid within one (1) year from the date of the Order; and six million dollars ($6,000,000) is to be paid within two (2) years from the date of the Order.

THIRD, eighteen million dollars ($18,000,000) of this civil penalty will be suspended as set forth in paragraph 19(b) of the Consent Agreement on the condition that Respondent applies this amount to Consent Agreement-authorised remedial compliance costs, in all instances determined as set forth in paragraph 19(c) of the Consent Agreement.

FOURTH, that any failure by Respondent to apply suspended penalty funds appropriately for remedial compliance measures or provide satisfactory accounting may result (in accordance with paragraph 19 of the Consent Agreement) in Respondent being required to pay immediately to the Department the entire amount specified, less credit for amounts the Department deems to have been properly applied and accounted for as expenditures in compliance with the Consent Agreement.

FIFTH, the Department recognises that Respondent agrees to waive its rights to raise the defence of statute of limitations with regard to the collection of the civil penalty imposed by the Consent Agreement and this Order, and that the statute of limitations shall be tolled until all terms of the Consent Agreement are satisfied.

SIXTH, that Respondent, and its assignees and successors, and in the event of reorganisation all affected entities or units, shall comply with the compliance measures and its obligations under the provisions of the Consent Agreement and shall do so within the deadlines established therein.

SEVENTH, that the Proposed Charging Letter, the Consent Agreement, and this Order shall be made available to the public.

Team Maverick.