Recent ITAR settlements involving BAE Systems and GE Aerospace (Settlements) show how administrative failures – such as lapses in technical-data controls, authorization management, employee training and internal oversight – can trigger major enforcement actions with multimillion-dollar penalties and years of regulatory oversight, even for sophisticated companies with mature export-control compliance programs. The Settlements also show that internal audits, voluntary self-disclosure, cooperation and remediation are linked to more favorable outcomes. This article discusses the Settlements and their compliance implications, with insights from export-control lawyers at Barnes, Richardson; Bass, Berry; and McGovern Weems. See our series on trade controls for compliance professionals: “Definitions” (Jul. 29, 2026), “The Enforcement Landscape” (Aug. 12, 2026), and “Which Companies Are at Risk” (Oct. 7, 2026).