The OverRuled: BIS Export Controls Module has been updated with the following actions:
- 31 Mar 2025 - ExHigh Air Space Ltd.; Geoffrey Chune Omariba; Nader Ali Saboori Haghighi - Denial Order; No monetary penalty
BIS issued a Temporary Denial Order (“TDO”) for a period of 180 days against ExHigh Air Space Ltd., Geoffrey Chune Omariba, and Nader Ali Saboori Haghighi (collectively, the “Respondents”) in relation to violations of the Export Administration Regulations (“EAR”). Specifically, Respondents sought to procure U.S. origin aircraft parts, including Inertial Reference Units classified under ECCN 7A103 and Engine Control Units classified under ECCN 9A991, and transshipped them to Russia without the required authorization from BIS. Respondents’ transactions involved Denied Persons on the BIS Denied Persons List. Furthermore, Respondents falsified shipping documentation to U.S. freight forwarders to avoid the Electronic Export Information filing requirements. Respondents also continued to engage in prohibited conduct by attempting to obtain additional aircraft parts from the United States for diversion to Russia even after repeated contacts and multiple seizures by federal law enforcement. BIS did not impose any monetary penalty.
- 31 Mar 2025 - Aviastar – TU - Denial Order; No monetary penalty
BIS renewed against Aviastar – TU (“Respondent”) a Temporary Denial Order (“TDO”) originally issued on April 2, 2024, for a period of one year in relation to violations of the Export Administration Regulations (“EAR”). Specifically, in issuing its original TDO, BIS found that Respondent was involved in operating multiple ECCN 9A991.b aircraft on flights into and out of Russia, after March 2, 2022, from/to China without the required BIS authorization. Further evidence indicated that Respondent operated aircraft subject to the EAR on domestic flights within Russia. BIS found that Respondent’s continued operation of these aircraft, even on domestic routes within Russia, presented a high likelihood of imminent violations that warranted imposition of a TDO. In the current TDO renewal, BIS determined that Respondent has continued to engage in a pattern of repeated, ongoing and/or continuous apparent violations of the EAR, including continued domestic flights and flights into and out of Russia from/to India. Therefore, BIS found that renewal of the TDO was necessary in the public interest to prevent an imminent violation.
The OverRuled: Russia Trade Controls Resource Center has been updated with the following actions:
- 02 Apr 2025 (BIS):
The U.S. Department of Justice ("DOJ") announced that Oleg Sergeyevich Patsulya, a Russian national, was sentenced to 70 months in prison for his role in a conspiracy to export controlled aviation technology to Russia and to launder money in connection with the illegal export scheme. Patsulya had pleaded guilty to conspiracy to violate U.S. export controls in connection with a scheme to acquire and unlawfully export controlled aviation equipment to Russian end users. He had also pleaded guilty to conspiracy to commit international money laundering. Patsulya's co-conspirator, Vasilii Sergeyevich Besedin, was previously sentenced to two years in prison for his role in the scheme.
- 31 Mar 2025 (BIS):
The Bureau of Industry and Security ("BIS") renewed its Temporary Denial Order ("TDO") on Russian airline Aviastar-TU ("Aviastar") for a period of one year.
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