The U.S. Department of State announced on August 13 that it had reached an administrative settlement with the U.S. arm of U.K. defense company BAE Systems to pay a $36 million civil penalty after breaching U.S. arms exports regulations more than 100 times.

The DoS and BAE said it reached the settlement following “an extensive compliance review” by the Office of Defense Trade Controls Compliance in the Department’s Bureau of Political-Military Affairs.

According to The Guardian, BAE’s 104 violations of the Arms Export Control Act and the International Traffic in Arms Regulations, included the unauthorized exports of technical data to multiple countries, including China, and violations of directorate of defense trade controls authorizations involving various countries.

BAE voluntarily disclosed all but one of the alleged violations, a substantial portion of which predated 2023. BAE 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, BAE 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 BAE’s compliance program. In addition, for an initial period of at least 24 months, BAE 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 the DoS statement said.

BAE Systems said it remained committed to ensuring full compliance with all applicable export control laws, and had “thoroughly cooperated” with the state department’s review.