“The Boeing Company was alleged to have violated the Arms Export Control Act, Pub. L. 90-629, and the International Traffic in Arms Regulations in connection with its involvement in the Wedgetail project… by violating the express terms and conditions of Department of State munitions license and other authorizations, by exporting defense articles and defense services without a munitions license or other authorization, and by omitting material facts from its applications for munitions licenses or other authorizations.” Boeing was ordered to pay a $3.8 million civil penalty and a suspended penalty of $400,000 to be applied toward the cost of compliance and monitoring measures over a three year period.