“The Department of Commerce… imposed a $2.12 million civil penalty against McDonnell Douglas [a subsidiary of Boeing]… as part of a settlement of charges that the company violated federal export control laws. The penalty is the maximum fine possible for the alleged violations.” McDonnell Douglas was alleged to have exported machine tools to China between 1994 and 1995 by submitting license applications containing false and misleading statements. “The Boeing Company assumes responsibility and liability for all exports under the Commerce Department’s jurisdiction made or to be made by McDonnell Douglas.”