Additionally, for at least the next 24 months, RTX will employ an external Special Compliance Officer to oversee the implementation of the Consent Agreement. This will include at least one external audit of RTX’s ITAR compliance program and the adoption of further compliance measures. 

Details Of The Violations 

Colby Badhwar, a journalist with the English-language version of the Russia-focused media outlet Insider, reported that most violations were committed by Rockwell Collins before its 2018 acquisition by Raytheon, now part of RTX. 

However, the violations spanned multiple RTX divisions, highlighting systemic compliance issues across the company. The proscribed destinations involved in these breaches included Iran, Lebanon, Russia, and China, underscoring the gravity of the violations. 

Many of the violations seem to stem from RTX employees traveling internationally while carrying their work laptops. 

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According to the State Department, these laptops contained a range of “defense articles” tied to critical US military programs, such as the Aegis Ballistic Missile Defense System, the B-2 Spirit bomber, the F/A-18 E/F Super Hornet, the F-35 Lightning II, and the Boeing E-3 AWACS. 

One key incident occurred in May and June 2021, when an RTX employee traveled to St. Petersburg, Russia, with an RTX-issued laptop loaded with ITAR-controlled technical data related to at least five military aircraft. 

During the trip, the employee noticed several cybersecurity alerts and reported them to the cybersecurity team. However, these alerts were “incorrectly dismissed” as false positives, likely due to the team’s transition to a new cybersecurity tool. 

This lapse in security protocols highlights the risks associated with inadequate cybersecurity measures, especially in regions with heightened surveillance.

In another case, an RTX employee traveled to Iran and attempted to log into his computer while in the country. RTX’s security team quickly detected and froze the laptop, but further investigation revealed that its hard drive contained highly sensitive technical data on the B-2 Spirit bomber and the F-22 Raptor fighter. 

The presence of such critical information in a sanctioned nation like Iran represents a severe breach of US security protocols, as this kind of data is typically heavily restricted to prevent its exposure to potential adversaries.

Another troubling incident involved an employee who made multiple trips to Lebanon. An internal RTX investigation later found that this employee’s laptop contained technical data on advanced missile systems, including the Standard Missile-3, Standard Missile-6, and ESSM missiles. 

In a 2023 disclosure, RTX revealed that in January 2023, it had improperly exported technical data related to an F-22 Raptor component without authorization. This data, which had been misclassified in March 2018, was sent to two Chinese employees at Collins’ Shanghai facility. 

The US government reviewed the files involved and concluded that this unauthorized export of technical data had compromised national security and negatively impacted a Department of Defense program of record.