Are Your Export Controls Built Into the System?

If a $36 million export violation comes down to whether a loading dock worker grabbed the right box, the problem isn’t the guy on the dock.

BAE Systems just paid $36 million to the State Department for more than 100 export control violations.

Here’s what makes this case worth your attention.

DDTC didn’t find willful evasion. It found something more common and, honestly, scarier: a well-intentioned compliance program that just couldn’t keep up.

GPS technical data sent to China because the file transfer system didn’t flag it, explosive mixture data sent to the UK because an employee thought it was already public, a shipment mix-up where dockworkers grabbed the wrong controlled part off the shelf.

DDTC’s own words: BAE lacked a compliance program that integrated corrective action across the enterprise.

Sounds familiar?

BAE had already done one audit, made improvements, and violations kept happening anyway.

Here’s my takeaway.

Partial fixes after an audit finding don’t close a systematic gap.

If your compliance program relies on individual judgment calls at the warehouse dock or the file transfer stage instead of built-in controls, you have the same exposure BAE just paid $36 million to resolve.

The Ethics and Compliance Q and A show is produced by One Stone Creative.