US Issues New Temporary Denial Orders Against Aircraft Parts Businesses

The United States has been investigating networks of businesses that are involved in exporting aircraft parts to Russia in violation of US sanctions. As a consequence of those investigations, the United States has issue several new Temporary Denial Orders (TDOs).

TDOs have larger consequence than merely stopping exports to the TDO parties. They also tend to inhibit acquisition of parts from the TDO parties, and may also affect services provided to TDO parties. Both of the TDOs in this case feature those expanded prohibitions against acquisition of goods and provision of services.

BIS issue the two Temporary Denial Orders (TDO) against two networks of companies accused of facilitating exports of aircraft parts to Russia through third countries in violation of U.S. export controls. The TDOs are dated today (June 12).

1. BIS issued a TDO against Turboshaft FZE, Treetops Aviation, Black Metal FZE, Timur Badr, and Elaine Balingit.
   • They are accused of exporting more than 500 shipments to Russia, including aircraft parts
   • The Russian recipients included an arm of Siberian Airlines, a company which is itself subject to a TDO  
2. BIS issued a TDO against Skytechnic, Skywind International Limited, Hong Fan International, Lufeng Limited, Unical dis Ticaret Ve Lojistik JSC, Izzi Cup DOO, Alexey Sumchenko, Anna Shumakova, Branmir Salevic, and Danijela Salevic.
   • They are accused of exporting approximately 260 shipments, the majority of which contained aircraft parts, to Russia
   • The Russian recipients included Pobeda Airlines, a Russian aviation company that is also subject to a TDO

If you are approached about buying or selling from any of these TDO entities, then you should review the regulations carefully before engaging in any sort of transaction: while a license to do business with a TDO party is possible, it is unlikely, absent exceptional circumstances.