Chitron, Revisited: Illegal Procurement Schemes Then and Now

From 2007 to 2010, I was the lead prosecutor responsible for the investigation and trial of Chitron Electronics, Inc. (“Chitron-US”), and two of its executives. Over a six-week trial, we proved to the jury that Chitron-US was a Chinese front company used to illegally export U.S. military and sensitive electronic components to the People’s Republic of China (“PRC”) over a period of more than 10 years. In November 2013, I wrote this article to provide suggestions on how to identify, dismantle, and successfully prosecute illegal procurement networks. I left the government in 2022 after serving as national security prosecutor for more than 18 years and the National Security Chief for the U.S. Attorney’s Office for the District of Massachusetts. I now assist clients in mitigating risks of all kinds, provide guidance on developing robust regulatory compliance programs, and specialize in handling high-stakes criminal and civil litigation matters and government enforcement proceedings. From my new vantage point, this article provides detailed insight and an inside view of a sophisticated procurement scheme, which exploited

loopholes in the U.S. supply chain.