Industry: | Government Contracting |
Underlying Misconduct: | International Traffic in Arms |
Matter Type: | Suspension & Debarment |
Relevant Jurisdiction(s): | Not Applicable |
Penalties: | Civil Penalties, Fine |
Fine Amount: | $42,000,000 |
Reporting Agencies: | Department of State |
Resolution Form: | Consent Agreement |
Agreement Date: | August 18, 2010 |
Monitor Reference Term: | Special Compliance Official |
Monitor Identity: | Wendy Wysong |
Monitorship Term: | 3 Years |
Monitor Selection Process: | Xe to nominate a person. Requires written approval of the Director, DTCC.
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Time to Propose Monitors: | 60 Days |
Time to Engage Monitor: | 75 Days |
Time to First Report: | 6 Months |
Reporting Frequency: | Semi-Annual |
Monitor Required Qualifications: | A "qualified" individual (not defined). Cannot have been employed in any prior capacity by or previously represented Xe or any of its subsidiaries or affiliates, past or present, in any capacity.
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Summary of Monitor's Scope: | Three principal areas of responsibility, which are too large for summary here. Please see Paragraph 16 of the Consent Agreement.
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Summary of Monitor's Activities: | Activities were significant - please see Consent Agreement for full details.
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Monitor's Restrictions: | No future employment or representation of Xe "for all time"
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Documents Uploaded: | https://iaicm.org/wp-content/uploads/formidable/Academi-LLC-Criminal-Information-21June20121.pdf, https://iaicm.org/wp-content/uploads/formidable/Academi-LLC-Statement-of-Facts1.pdf, https://iaicm.org/wp-content/uploads/formidable/Academi-Blackwater-DOJ-DPA-7Aug20121.pdf, https://iaicm.org/wp-content/uploads/formidable/Xe-Services-Consent-Agreement-DDTC-18Aug20101.pdf, https://iaicm.org/wp-content/uploads/formidable/Xe-Services-Proposed-Charging-Letter-13Aug2010.pdf |
Other Relevant Information: | https://iaicm.org/wp-content/uploads/formidable/Clifford-Chance-Partner-Wendy-Wysong-Appointed-Special-Compliance-Officer-for-Xe.pdf, https://iaicm.org/wp-content/uploads/formidable/Xe-Services-LLC-Enters-Civil-Settlement-of-Alleged-Violations-of-the-AECA-and-IT.pdf |
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