Raytheon Company was a global aerospace and defense company headquartered in Waltham, Massachusetts. Raytheon's shares were registered with the SEC and publicly traded on the New York Stock Exchange. In 2020, Raytheon merged with United Technologies Corp. (UTC), after which Raytheon became a wholly owned subsidiary of UTC. The new merged company took the name of Raytheon Technologies Corp., and some time later it changed its name to RTX Corporation. RTX is the successor in interest of Raytheon but not a named defendant in this action.
Thales-Raytheon Systems Company LLC was formed in 2001 as a joint venture between Raytheon and the French defense company Thales Group. Thales-Raytheon had two major operating subsidiaries, one of which was controlled by Raytheon and a component of Raytheon's Network Centric Systems and then Integrated Defense Systems business.
According to the documents in this case, between 2012 and 2017, Raytheon conspired to offer and pay bribes to a high level official in the Qatar Emiri Air Force. Raytheon paid at least some of these bribes through Thales-Raytheon and local Qatari agents. Among the contracts Raytheon secured or attempted to secure through these bribes were four supplemental additions to a 1998 contract between Raytheon and the Gulf Cooperation Council, an intergovernmental union of six member states in the Middle East, and a sole-source contract to build a joint operations center that would interface with Qatar's several military branches. This second contract was cancelled, and the bribes were offered but not paid. As a result of these schemes, Raytheon profited by approximately $36.7 million and would have expected to earn over $72 million more if the joint operations center contract had come to fruition.
On October 16, 2024, the DOJ filed a two count information in the Eastern District of New York against Raytheon alleging conspiracies to violate the antibribery provisions of the FCPA as well as the Arms Export Control Act (AECA). On the same date, Raytheon and RTX entered into a deferred prosecution agreement with the DOJ with a term of three years. Under the terms of the settlement, Raytheon agreed to pay a criminal penalty of $230,400,000 and forfeiture of $36,696,068 in connection with the FCPA charge and an additional criminal penalty of $21,904,850 in connection with the AECA charge. The DOJ agreed to offset up to $7,400,090 of the forfeiture against disgorgement paid in the SEC's parallel proceeding. The criminal penalty represents a 20 percent discount from the 20th percentile of the Sentencing Guidelines range. In addition to the monetary sanctions, Raytheon and RTX agreed to hire an independent compliance monitor for the duration of the DPA. The DOJ noted Raytheon's cooperation and remediation but pointed out that the company failed to disclose the misconduct and initially was slow to respond to requests for information and withheld relevant, material information and gave misleading presentations to the DOJ.
