Buying Blue Canyon can bring RTX compliance obligations—even though the contract says Blue Canyon did not cause the allegations.

The Blue Canyon purchase agreement links two easily missed provisions. Section 3.13(d) says the DDTC allegations did not arise from the acquired business's activities. Section 5.24 nevertheless assigns consent-agreement responsibilities to the buyer group, subject to written exceptions or waivers. The underlying 2024 State Department agreement explains the connection: paragraph 5 extends responsibilities when covered ITAR businesses change hands, unless an exception is approved. RTX settled without admitting or denying the allegations. The purchase agreement requires efforts to obtain a waiver, but expressly makes obtaining one before closing unnecessary. Compliance responsibility and responsibility for the original conduct are different questions.