The Bureau of Industry and Security announced June 13 a $285,000 civil penalty against a company headquartered in Türkiye for violating controls on exports to Russia.
As part of the U.S. response to Russia’s war against Ukraine, effective Feb. 24, 2022, BIS imposed expansive controls on exports of aviation-related items to Russia, including a license requirement for the export, reexport, or transfer (in-country) to Russia of any aircraft or aircraft parts specified under any export control classification number.
Additionally, effective March 2, 2022, BIS excluded any aircraft registered in, owned by, controlled by, or under charter or lease by Russia or a national of Russia from being eligible for export or reexport to Russia pursuant to license exception AVS (aircraft, vessels, and spacecraft). As a result, any U.S.-origin aircraft or foreign aircraft that includes more than 25 percent controlled U.S.- origin content, and that is registered in, owned by, controlled by, or under charter or lease by Russia or a national of Russia, is subject to a license requirement before it can be exported or reexported to Russia.
According to BIS, the company at issue admitted that it violated these restrictions by flying a U.S.-origin aircraft into Russia for private charter flights arranged by Russian nationals without the required BIS license. BIS notes that although the passengers provided payment through third-party non-Russian charter brokers, the flights were nevertheless controlled by or under charter or lease by a Russian national and were therefore ineligible for license exception AVS.
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