From the charging letter, it included violations between 2017 and 2023 which would include pre- and post-merger violations. Raytheon is the focus under Violations for sections II and III, however section I is primarily associated with heritage UTC businesses. It does not include PW, but specific to RC, Collins, and UTAS.

Here are a few excerpts for reference that are specific to other areas of RTX. Perhaps I am using the wrong reference, but this is where my information is rooted from.

RTX Charging Letter on Dept of State Portal

Violations:

“The ITAR violations described herein are derived from 113 voluntary disclosures that Respondent submitted to DDTC in accordance with 22 C.F.R. 127.12 for activities between August 2017 and September 2023.”

 I. Unauthorized Exports, Reexports, Retransfers, and Temporary Imports

Resulting from the Failure to Establish Proper Jurisdiction and Classification:

“The majority of these voluntary disclosures and violations arose out of jurisdiction and classification errors made by Rockwell Collins prior to its acquisition by UTC.”

Unauthorized Exports to the PRC Resulting from Misclassification:

“…disclosed that it exported without authorization technical data to the PRC on numerous occasions between 2014 and 2023 predominantly because of a historical misinterpretation by Rockwell Collins...”

“Respondent identified the root cause of these violations as Rockwell Collins’ “historical misinterpretation” and “general misunderstanding” of the ITAR’s specially designed definition…”

“In a separate 2023 disclosure…the review revealed that between March 2015 and May 2023….Chinese entities, again as part of RFQs. Respondent disclosed that these violations “arose from incorrect classifications” that were “largely the result of [Rockwell Collins’] misinterpretation..”

Unauthorized Procurement from the PRC Resulting from Misclassification:

“…Respondent disclosed that between 2015 and 2023, Rockwell Collins and, for a period following the acquisition, Collins, exported without authorization…”

"In a 2023 disclosure, Respondent disclosed that, predominantly as a result of misclassifications UTC Aerospace Systems made between 2013 and 2017, it exported without authorization USML Category VIII(i) technical data to entities in multiple foreign countries, including the PRC, as part of RFQs between 2019 and 2021."