The company said Raytheon, its wholly owned subsidiary, entered into a DPA-1 with the DOJ on October 15, 2024, under which the DOJ will defer criminal prosecution for conspiracy to violate the FCPA's anti-bribery provisions and conspiracy to violate the AECA for 3 years. The DPA-1 includes a criminal penalty and forfeiture totaling $282 million.

8-KOther EventsFiled Oct 16, 2024Period of report Oct 15, 2024Summary published (UTC) Oct 25, 2026

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The company said Raytheon, its wholly owned subsidiary, entered into a DPA-1 with the DOJ on October 15, 2024, under which the DOJ will defer criminal prosecution for conspiracy to violate the FCPA's anti-bribery provisions and conspiracy to violate the AECA for 3 years. The DPA-1 includes a criminal penalty and forfeiture totaling $282 million.
It said it became subject to an SEC administrative cease-and-desist order on October 16, 2024, and the SEC found that Raytheon violated the FCPA's anti-bribery, books and records, and internal controls provisions. The order requires a payment of $102 million, including disgorgement, prejudgment interest on disgorgement, and a civil penalty, within 14 calendar days.
The company said its subsidiary Raytheon entered into a DPA-2 and an FCA settlement agreement with the DOJ on October 16, 2024 to resolve claims of defective pricing on certain legacy contracts. The criminal penalty under DPA-2 is $147 million, and the FCA settlement payment, which includes restitution and interest, is $428 million.
The company said Raytheon and the company are required under DPA-1, DPA-2, and the SEC administrative order to retain independent compliance monitors satisfactory to the DOJ and the SEC and to undertake compliance self-reporting for 3 years. It also said the amounts to be paid are consistent with those accrued as of June 30, 2024 and disclosed in its Form 10-Q.

Summary

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Analysis scope · Filing body only (exhibits excluded)We analyzed the filing body only. The exhibits exceeded the length limit and were excluded, so figures, financial statements and presentation materials in them were not reviewed.

DPA-1: Three-Year Deferred Prosecution Under FCPA and AECA

The company said Raytheon, its wholly owned subsidiary, entered into a DPA-1 with the DOJ on October 15, 2024, under which the DOJ will defer criminal prosecution for conspiracy to violate the FCPA's anti-bribery provisions and conspiracy to violate the AECA for 3 years. The DPA-1 includes a criminal penalty and forfeiture totaling $282 million.

Source · Based on the filing body (exhibits excluded)

SEC Order Finds FCPA Violations and $102 million Payment

It said it became subject to an SEC administrative cease-and-desist order on October 16, 2024, and the SEC found that Raytheon violated the FCPA's anti-bribery, books and records, and internal controls provisions. The order requires a payment of $102 million, including disgorgement, prejudgment interest on disgorgement, and a civil penalty, within 14 calendar days.

Source · Based on the filing body (exhibits excluded)

DPA-2 and FCA Settlement: Legacy Contract Matters Involve $147 million and $428 million

The company said its subsidiary Raytheon entered into a DPA-2 and an FCA settlement agreement with the DOJ on October 16, 2024 to resolve claims of defective pricing on certain legacy contracts. The criminal penalty under DPA-2 is $147 million, and the FCA settlement payment, which includes restitution and interest, is $428 million.

Source · Based on the filing body (exhibits excluded)

Independent Compliance Monitors Named; Payments Match Existing Accruals

The company said Raytheon and the company are required under DPA-1, DPA-2, and the SEC administrative order to retain independent compliance monitors satisfactory to the DOJ and the SEC and to undertake compliance self-reporting for 3 years. It also said the amounts to be paid are consistent with those accrued as of June 30, 2024 and disclosed in its Form 10-Q.

Source · Based on the filing body (exhibits excluded)

AI summarized the filing and translated the summary into English; it may differ from the original. For reference only, not investment advice. AI translated the published Korean report into English. Figures are copied as filed, not recalculated.

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