It was alleged that Boeing violated the Arms Export Control Act, Pub. L. 90-629, and the International Traffic in Arms Regulations by exporting technical data and defense services to Russia, the Ukraine, Norway and Germany “without the required approvals from the Department [of State] and, in other circumstances, violated the terms and conditions of approvals that were provided by the Department.” Boeing was ordered to pay a civil penalty of $7.5 million and a suspended penalty of $2.5 million to be applied to the costs of compliance measures over a three year period.