Xe Services, LLC (also known as Blackwater Worldwide), a provider of private security services, entered into a consent agreement with the DDTC to settle allegations of 288 violations of the ITAR involving the unauthorized export of defense articles and provision of defense services to foreign end-users in multiple countries between 2003 and 2009. Xe Services agreed to pay a US$42 million civil penalty, US$12 million of which will be suspended if applied to pre- and post-consent agreement remedial measures. Xe Services has replaced senior management, established an independent export compliance committee to oversee its ITAR compliance efforts, improved its ITAR compliance procedures, provided various ITAR training and conducted a targeted ITAR audit to ensure the effectiveness of its compliance measures. Xe Services also agreed to resolve any outstanding allegations, institute external oversight of its compliance measures, and continue to improve its compliance measures. For these and other reasons, the DDTC decided not to pursue administrative debarment and rescinded the general policy of denial on license applications with respect to Xe Services. However, the DDTC did note in its proposed charging letter that it likely would have proposed more significant charges against and penalties upon Xe Services if the DDTC had “not taken into consideration Respondent’s Voluntary Disclosures, remedial compliance measures, cooperation in the latter part of the investigation, change in management, support of US government programs, and the absence of disclosure of sensitive technologies or actual harm to national security as significant mitigating factors.”