When assessing the sanction, DDTC took into account a number of mitigating factors such as the filing of VODs, the company`s agreement to pay the legal deadline, and self-initiated improvements to the compliance program during the DDTC audit. Nevertheless, DDTC also considered aggravating factors such as significant deficiencies in the compliance program and internal control; lack of ITAR expertise and management oversight during VSD periods; the lack of investigation, detection and disclosure of offences; the frequency and repetition of offences; and the inability to implement compliance measures presented by DDTC in VOD submissions. So, what is a consent agreement and why is it important? An approval agreement describes the “measures needed to improve compliance programs.” [2] This is not an admission of guilt, but a comparison between government and business. As the L3Harris agreement makes clear, VODs are not necessarily required to mitigate alleged infringements in all circumstances. Companies must take the necessary measures to comply with the applicable rules and also be conscientiously vigilant in the event of notification of errors or errors. If not, consent agreements can serve as a public and costly reminder of a company`s compliance errors. FLIR also failed to reflect corporate reorganization in new licensing and existing licensing and agreements. Flir therefore exported defense products and provided defense services in licenses and agreements that did not reflect the role of the new subsidiary in the ITAR violation. [2] Definition of Consent Agreements, Sanctions and Monitoring Agreements, of the Defence Trade Trade Controls Directorate, www.pmddtc.state.gov/ddtc_public?id=ddtc_kb_article_page&sys_id=384b968adb3cd30044f9ff621f961941. L3Harris` approval agreement with DDTC offers five valuable insights for all defense exporters: On April 24, 2018, FLIR Systems, Inc. .