
RTX Resolves Corruption Allegations
FRA supported RTX and counsel in FCPA related fine calculations.
In October 2024, RTX (a US-based defense contractor formerly known as Raytheon Technologies Corp.) agreed to pay approximately $1 billion to the US DOJ and US SEC to resolve investigations pertaining to:
(i) an alleged fraud scheme involving “defective pricing on certain government contracts", and
(ii) alleged US Foreign Corrupt Practices Act (FCPA), Arms Export Control Act (AECA) and International Traffic in Arms Regulations (ITAR) violations.
(DOJ press release, 16 October 2024)
(SEC press release, 16 October 2024)
External counsel retained FRA to support RTX’s FCPA-related negotiations with the US authorities. In this matter, the team’s primary focus was the submission of profitability assessments relating to certain long-term company contracts. Specialists from our US and UK offices analyzed revenues and expenses to assess the profitability of contracts the company held and planned to execute within the Middle East, where the alleged actions took place.
The analyses involved extensive review of company accounting policies, historical and pro forma financial records, bid documentation, project management documentation, and technical accounting practices. While conducting the analyses, FRA regularly interfaced with the US DOJ and US SEC, providing timely responses to accounting-related requests and support of the company’s cooperation throughout the investigations.