Export Enforcement is Earning High Level Attention

September 24, 2024 by Leave a comment

The G7 is taking an interest in export enforcement, and this could affect everyone in aviation.

The G7 has announced new cooperation and new guidance for the world’s exporting community. The G7 is comprised of Canada, France, Germany, Italy, Japan, the United Kingdom, and the United States. The European Union also participates in the Group.

The G7 Sub-Working Group on Export Control Enforcement met today (September 24) and published new guidance on the prevention of diversion of high priority goods to Russia. Russia is a particular focus of this group partly because of the Ukrainian invasion, but also partly because of the significant efforts that Russia has made to circumvent sanctions.

The identified high priority goods included aircraft parts (Tariff Code 8807.30), avionics (Tariff Code 9014.20) and other navigational instruments and appliance (Tariff Code 9014.80). Thus, this reaffirms that aviation is a high priority target for diversion and it is also a high priority target for government enforcement.

The newest G7 guidance includes a list of red flags that should cause additional scrutiny if they arise in your transactions:

  • Sudden changes in business activity after 24 February 2022, or after subsequent changes in export controls/sanctions
  • False, inaccurate, or missing documentation
  • Concealing the end user (remember, there is a U.S. legal obligation to show end use compliance when exporting aircraft parts intended for installation on foreign aircraft (15 C.F.R. § 744.7))
  • Inconsistencies in the transaction
  • Vague details and/or incomplete information
  • Dividing an invoice value into smaller amounts to remain under value limits of sanctioned goods or export controls
  • Suspicious customer information
  • Customer has connections of concern
  • Concerning business practices
  • Last-minute changes to parties involved with the transaction from an entity in Russia or Belarus to an entity in another country
  • Payments from entities located in third countries that are not otherwise involved with the transactions, particularly through a sanctioned country
  • Customer unwilling to provide certification that it will not sell items to Russia or sanctioned parties in third countries

There are examples in the G7 document for each of these bullets so be sure to click through and look at the full list of red flags and examples. Many of the latest red flag examples represent fact patterns that we’ve seen arise in the aviation community.

There is also a recommended due diligence outline in the G7 document, but this is a very short outline that might be inadequate for most aircraft parts transactions subject to U.S. law.

The Aviation Suppliers Association will be covering export compliance analysis and due diligence topics during its popular Export Week! seminars on October 7-11, 2024. These are short (30 minutes of content followed by a 15 minute question period) lunch-time (11:30 am eastern time) session designed to educate the community about export compliance without overwhelming the audience with jargon and a mountain of regulations. The seminars are free for ASA members! I hope to see you all, there!

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Export Record Retention Changes from Five to Ten Years

September 11, 2024 by Leave a comment

The Office of Foreign Asset Control (OFAC) plans to issue a new rule that will extend the record retention requirements for export records from five years to ten years (this is found in 31 C.F.R. § 501.601).

The OFAC rule change will likely be published as an interim final rule. This means that it will be published as a direct-final rule without a notice of proposed rulemaking. The OFAC rule is expected to be published on Friday (September 13, 2024) and is expected to be effective 180 days later (probably March 12, 2025).

One of the reasons for this interim-final process is because this record keeping obligation is described by OFAC as a foreign affairs function. Foreign affairs functions are excepted from the requirements of the Administrative Procedures Act (5 U.S.C. § 553(a)(1)), including the requirement for prior notice on a published rule.

The reason for these record keeping extensions is because a law issued earlier this year (Public Law No. 118-50, section 3111) established a ten year statute of limitations for sanctions violations (codified at 50 U.S.C. § 1705(d)). Please note that the statute did not mandate a ten year record retention – this choice was made by OFAC; but commercial record retention decisions are often made based around statutes of limitations.

One of the changes to the rules will extend the penalty for late-filed reports (found in the enforcement guidelines). Now the penalty will continue to increase monthly for ten years.

OFAC plans to collect comments on the interim-final rule. OFAC is expected to specifically request comments on the following topics:

  • Whether the collection of information is necessary for the proper performance of the functions of the agency, including whether the information has practical utility;
  • The accuracy of the agency’s estimate of the burden of the collection of information;
  • Ways to enhance the quality, utility, and clarity of the information to be collected;
  • Ways to minimize the burden of the collection of information on respondents, including through the use of automated collection techniques or other forms of information technology; and
  • Estimates of capital or start-up costs and costs of operation, maintenance, and purchase of services required to provide information

We expect there to be a 30 day comment period that will begin when the rule is published. ASA members who are interested in being involved in the Association’s information-gathering and response process should contact ASA Counsel Jason Dickstein immediately. This change in the record retention period may also influence a change in ASA-100 record retention practices.

BIS may also choose to extend its record retention period consistent with the sanctions statute of limitations; however they have not yet chosen to do so. At present, the BIS record retention period rule remains five years. The OFAC record retention requirement, though, should effectively apply to most U.S. exports handled by the aircraft parts community.

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BIS Recommends New Export Screening Steps

July 10, 2024 by Leave a comment

Today, the Department of Commerce’s Bureau of Industry and Security (BIS) has published new guidance reminding the export community about the dangers of divergence of goods to Russia.  This new BIS guidance outlines additional recommendations for screening transactions.

High Priority List (Including Aircraft Parts)

BIS has identified a list of 50 Common High Priority List (CHPL) items.  These are items that Russia has been procuring to support its weapons programs.  For this reason, these 50 items have been identified as special focus items for scrutiny to avoid divergence of shipments to Russia.  This list includes aircraft parts (particularly those subject to HTSUS 8807.30), bearings (particularly those subject to HTSUS Heading 8482) and certain instruments and appliances subject to HTSUS Heading 9014. Exporters should be sure to look at the full list to get an idea of the full scope of this CHPL list.

The CHPL list is meant to drive a heightened scrutiny of certain transactions, to ensure that they cannot be diverted to Russia.  BIS expects that exporters will ensure compliance for every export, but has asked for extra diligence in the scrutiny applied to transaction in the 50 CHPL articles.

Additional Screening Recommendations

BIS has recommended that for CHPL items, exporters screen the transaction parties against the Trade Integrity Project (TIP) website.

The TIP website includes a list of companies that have exported certain materials into Russia.  TIP was developed by the UK-based Open-Source Centre for monitoring trade with Russia. The TIP website specifically focuses on trade in CHPL items, and displays entities that have shipped CHPL items to Russia since 2023. It is based on publicly available trade data. TIP does not reflect all exports into Russia, and it may not include some companies that have exported aircraft parts into Russia.  The TIP website is meant to support export diligence investigations, but it should not be your only resource.

We have recommended Import Genius as another good resource for identifying companies that have exported goods to Russia; but we have also warned that this is also a starting point for scrutiny; we have heard about U.S. companies who are falsely listed as the source of goods by the actual exporters, so it is important to check out the data you find. Using Import Genius is NOT part of the latest BIS screening recommendation.

If you discover that the partner in question has been selling to Russia, then this may reflect a red flag that needs to be cleared before the transaction can be completed. For example, if you are selling to a distributor who is on the TIP list, but they ask you to drop ship the goods directly to a legal end user in a place like the UK (particularly if you get a signed end-use-statement from the end user validating the compliance elements), then this might be sufficient to clear a red flag that would otherwise casts a shadow over other transactions.

BIS Warning Letters

BIS is issuing two different types of letters to warn companies about their business partners who may be violating US export laws:

  • Red Flag Letters
  • Is Informed Letters

If BIS believes that one of your partners may have violated the export laws (such as by illegally diverting goods to Russia) then BIS may send you a “red flag” letter. A “red flag” letter informs you of the BIS suspicions, and imposes on your company an additional burden to clear the red flag before continuing to do business with the partner. A company that receives a “red flag” letter should conduct additional due diligence to resolve and overcome the red flag identified by BIS before filling an order from the identified partner.

BIS may inform you that a license is required for export, reexport or transfer of items to a specified end-user because BIS has determined that there is an unacceptable risk of diversion (e.g. because of a threat of diversion to a military end user in a restricted country). This is known as an “Is Informed” letter. When you receive this sort of communication, then you are typically required to comply with the restriction (if the communication is oral then it will usually be followed by a written communication within two days). In most cases, this means that you will need a license for the transaction, and it may cancel prior licenses. From an enforcement perspective, non-compliance with an “is informed letter” is treated the same as non-compliance with any other license requirement under the regulations and may be subject to penalties.

If you receive a “red flag” letter or an “is informed” letter than you should coordinate your actions with an export attorney.

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Emperor Aviation Removed from SDN List

May 8, 2024 by Leave a comment

The US government has removed Emperor Aviation from its list of specially designated nations (SDNs). This is effective May 3, but it is expected to be published tomorrow in the Federal Register. This will also remove from the SDN list certain registry numbers from the Emperor Aviation fleet that were previously listed under the SDN list.

Emperor Aviation is based in Malta but was alleged to have Russian connections as well.

Please note that exports of aircraft parts to Russia are still subject to sanctions under other regulations, like Russian and Belarusian industry sector sanctions which apply to certain parts based on their harmonized tariff codes, and the Sanctions against Russia and Belarus, which apply to export to Russia of any item subject to the EAR and specified in any Export Control Classification Number (ECCN).

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New Treasury Export Reporting Procedures

May 8, 2024 by Leave a comment

The Treasury Department’s export-related functions will soon eliminate paper filings in favor of electronic filings. The Office of Foreign Asset Control (OFAC) plans to issue the new rule in this Friday’s Federal Register.

The current OFAC regulations set forth standard reporting and recordkeeping requirements, license application procedures, and other procedures relevant to the export programs administered by OFAC. OFAC is amending several regulations to require electronic submissions and to remove options for mail submission. The rule change will remove the addresses for physical delivery of such correspondence, and require such correspondence to be communicated electronically according to the new regulatory instructions. Some of the reporting mechanisms that are changed by the rule will be:

  • Annual Reports of Blocked Property (31 C.F.R. § 501.603(d))
  • Reports of rejected transactions (31 C.F.R. § 501.604(d))
  • Required notice to the government of litigation that may affect blocked property or retained funds (31 C.F.R. § 501.605)
  • Seeking export licenses (31 C.F.R. § 501.801)
  • Petitioning for rulemaking (31 C.F.R. § 501.804)
  • Seeking records under the Freedom of Information Act (FOIA) (31 C.F.R. § 501.805)
  • Petitioning for the unblocking of property (31 C.F.R. § 501.806)
  • Petitioning to be removed from a SDN or blocked person list (31 C.F.R. § 501.807)

The rule is expected to be issued as an interim final rule on Friday. This means that the rule will be issued as a direct final rule, but the public is allowed to comment on the final rule, and a subsequent change could be made based on public comments.

The rule is expected to be effective 90 days after publication (if everything stays on schedule then that means August 9, 2024).

If you complete your filings electronically, then be sure to maintain evidence to prove that the filing was properly made. This can include screen shots, copies of sent emails with routing information, etc.

Resources

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US Changes Export Licensing Requirements for Certain Aircraft Parts Transactions

May 1, 2024 by Leave a comment

The United States has changed the export licensing standards for aircraft parts bound for Australia and/or the United Kingdom (“UK”). This is being accomplished under the recently-published AUKUS rules. There are two main changes:

  • Elimination of most destination-based licensing restrictions when exporting to Australia or the UK (in the Commerce Country Chart)
  • Expansion of the AVS exception for aircraft parts bound for Australia and the UK

Commerce Country Chart Changes

Under the exporting rules, the exporter must look at the export destination and compare it to the reason for control in the Commerce Country Chart. The licensing obligations for Australia and the UK have changed dramatically!

The United States has removed the licensing obligations for all articles being exported to Australia or the UK except for articles controlled for chemical or biological weapons reasons under column “CB1” (which still require a license).

One of the common aircraft articles that may be affected by this rule change is inertial reference units (IRUs) which are export-controlled for missile technology (“MT1”) reasons. Until the recent rule change, an article controlled under the MT1 provisions needed an export license when exported to any jurisdiction other than Canada. The new rule adds Australia and the UK to the list of exceptions where the destination does not drive a license obligation for MT1 exports (this is also codified at 15 C.F.R. § 742.5(a)(1)).

This would also affect many 600-series articles (defense articles) destined for Australia or the UK, because the Australian and UK restrictions on exports controlled for reasons of regional stability (RS) and national security (NS) have also been removed.

Other licensing provisions may still apply! For example, if the aircraft parts is ordered by a business on the BIS entity list then a license will be required for the transaction, even if that company is located in the UK.

License Exception AVS

The rule change also expands the utility of license exception “AVS.”

Previously, license exception AVS applied (inter alia) to exports of aircraft parts for use on U.S. or Canadian registered airplanes, as long as they are ordered by the owner/operator and the aircraft is not located in Cuba or a Country Group D:1 nation (excluding China). This has been expanded to include parts ordered by the owners/operators of Australian-registered aircraft and UK-registered aircraft. See 15 C.F.R. § 740.15(c)(1).

AVS also allowed US and Canadian airlines to order aircraft parts to be exported to their installations (e.g. airline-operated line stations) and their agents (such as an MRO). This exception has been expanded to include Australian airlines and UK airlines. This may not be used to export to Cuba or a Country Group D:1 nation (excluding China). See 15 C.F.R. § 740.15(c)(2).

Hot Section Technology

As an additional relevant note, the United States has also removed restrictions on the export of certain engine technology to Australia or the UK. This is limited to hot section technology for the development, production or overhaul of commercial aircraft engines controlled under certain subsections of ECCN 9E003. This matches Australia and the UK with the export treatment of Canada for this technology.

Public Comments

These changes are part of an interim final rule. This means that the rule was published and becomes immediately effective, but the rule is open to public comment. Public comment remains open until June 4.

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Special Rules for Aircraft Parts Exports

July 27, 2023 by Leave a comment

Do you export aircraft parts? If you do, then you may need to complete the EXTRA compliance checks that apply to foreign aircraft. Often, the export compliance analysis required leads to a need to specifically identify the foreign aircraft on which the parts will be installed.

When you export aircraft parts from the U.S., and the parts are intended for installation on a foreign registered aircraft, you need to perform an extra layer of analysis to ensure export law compliance. The U.S. export regulations specify that you need to identify and check all of these locations:

  • The country to which the part is being exported (which is part of the normal export assessment);
  • Any intermediate nations (also part of the normal export assessment);
  • The country in which the foreign aircraft is located (15 C.F.R. § 744.7(a)(1));
  • The country in which the aircraft is registered – you can often check the tail number against the country’s aircraft registry to confirm this information (15 C.F.R. § 744.7(a)(2));
  • The country which is currently controlling, leasing, or chartering the vessel or aircraft (this applies if a nation has operational control of the aircraft) (15 C.F.R. § 744.7(a)(3)); and
  • The country of the person who is currently controlling, leasing, or chartering the aircraft (this applies if a person has operational control of the aircraft – this country can be the incorporation location of a business or the nationality of a natural person) (15 C.F.R. § 744.7(a)(3)).

For each of the locations that you identified based on the bullet points above, you need to assess whether you can export to that location without a license (“No License Required” or “NLR”), or under an applicable license exception. If the answer is “no” for any of the locations, then the transaction typically needs to be licensed.

As an example, assume that you are exporting a garden-variety aircraft part for installation in a private aircraft that is registered in Ireland and owned by an Irish leasing company. The part is controlled under ECCN 9A991. The aircraft is currently located in Ireland, where it is awaiting service at an Irish repair station. The aircraft is leased and operated by a Russian citizen. You need to perform an analysis of this export as if it were going to Ireland (which it is) and also as if it were going to Russia. There is typically no license required to export this part to Ireland, but exporting the same part to Russia is restricted under the Russia/Belarus rules. Because of the interaction between the Russia/Belarus rules (15 C.F.R. § 746.8) and the foreign aircraft rules (15 C.F.R. § 744.7), a license would be required to export this part for installation on an aircraft controlled/leased by a Russian citizen. Note that this transaction would not be able to benefit from license exception AVS under the limits of the Russia/Belarus rules (15 C.F.R. § 746.8) because of the specific limits imposed on AVS under that rule.

What about a foreign airline that wants to obtain parts for stock? If that airline only flies non-U.S. registered aircraft, and the part is destined for installation on their fleet, then you reasonably know that the part is destined for installation on a non-U.S. registered aircraft and you ought to be performing this analysis. Ask the airline to verify that the part will only be used on their fleet (confirm the countries of registry for their fleet), and ask them to identify where their maintenance is performed (location of aircraft at time of installation). The jurisdictions identified (registry, aircraft location and operator’s nationality) can be scrutinized to determine whether the requirements of 744.7 are met for the entire fleet; this allows you to support the airline without knowing the specific identity of the target aircraft.

What about domestic transactions? The foreign aircraft rule only applies to export transactions to, or for the use of, a foreign aircraft. So it does not apply to domestic (non-export) transactions, including domestic transactions that anticipate installation on a foreign aircraft while it is legally in the United States. But there are exceptions, including the one we will cover in the next paragraph.

What if I am selling to someone that I know will violate the export laws? It is important to remember that if you support someone else’s export, while knowing that they intend to violate the export laws, then this is also a violation. This restriction is known as General Prohibition Ten. It means that if you sell a part to someone else, knowing that they intend to export it illegally, then you have committed a violation, yourself.

Let’s look at an example: S7 Airlines is currently subject to a temporary denial order under the Export Administration Regulations. You are contacted by a U.S.-based distributor who tells you that it is buying parts for export to S7 Airlines. The part that the distributor is seeking from you is subject to the Export Administration Regulations (most civil aircraft parts are subject to the Export Administration Regulations). This distributor asks you to engage in a wholly domestic transaction by shipping the part to their location in New Jersey. If you sold a part entirely within the United States, to a domestic distributor, after that distributor had said that it intends to export the part to S7 Airlines (who is subject to a BIS denial order), then you would have violated General Prohibition Ten, even though your transaction was not an export. The reason for this is because your sale is made with knowledge that the aircraft part will be exported in violation of the Export Administration Regulations.

Conclusion

Exporting aircraft parts is tricky and sometimes an aircraft part export transaction requires special research and analysis to identify the correct compliance path. There can be more than one regulatory regime that applies to the transaction. If you are not sure whether you are doing the right thing, then take a step back and make sure that you are complying with the correct laws and regulations.

ASA has a number of resources to support your efforts. We provide export compliance training on a regular basis – ASA is next planning to hold export compliance training for its members in October.

My law firm also supports export compliance by helping companies to build compliance systems, by auditing their existing compliance systems, and by analyzing tough transactions to help identify the correct compliance path (we also support companies in seeking licenses from the US government, as necessary).

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US Government Identifies Red Flags for Detecting Sanctions Evaders

March 27, 2023 by Leave a comment

The Departments of Commerce, State and Treasury have issued a joint memo warning the community about sanctions evasion and identifying “red flags” that should result in additional scrutiny.

The Compliance Note is specifically published to identify common red flags that can indicate a third-party intermediary may be engaged in efforts to evade U.S. sanctions or U.S. export controls. Red flags are fact patterns that suggest a transaction may violate the U.S. export regulations. When red flags are encountered, it is important to perform additional inquiry in order to identify whether the red flag indicates a reasonable suspicion of a violation, or whether the apparent issue can be cleared because inquiry shows that the fact pattern does not – in fact – reflect a violation..

The following export transaction red flags are identified in the text and republished verbatim:

Common red flags can indicate that a third-party intermediary may be engaged in efforts to evade sanctions or export controls, including the following:

  • Use of corporate vehicles (i.e., legal entities, such as shell companies, and legal arrangements) to obscure (i) ownership, (ii) source of funds, or (iii) countries involved, particularly sanctioned jurisdictions;
  • A customer’s reluctance to share information about the end use of a product, including reluctance to complete an end-user form;
  • Use of shell companies to conduct international wire transfers, often involving financial institutions in jurisdictions distinct from company registration;
  • Declining customary installation, training, or maintenance of the purchased item(s);
  • IP addresses that do not correspond to a customer’s reported location data;
  • Last-minute changes to shipping instructions that appear contrary to customer history or business practices;
  • Payment coming from a third-party country or business not listed on the End-User Statement3 or other applicable end-user form;
  • Use of personal email accounts instead of company email addresses
  • Operation of complex and/or international businesses using residential addresses or addresses common to multiple closely-held corporate entities;
  • Changes to standard letters of engagement that obscure the ultimate customer;
  • Transactions involving a change in shipments or payments that were previously scheduled for Russia or Belarus;
  • Transactions involving entities with little or no web presence; or
  • Routing purchases through certain transshipment points commonly used to illegally redirect restricted items to Russia or Belarus. Such locations may include China (including Hong Kong and Macau) and jurisdictions close to Russia, including Armenia, Turkey, and Uzbekistan.

Remember that these are general transactional red flags published by the US government, so their applicability to aviation may vary. Further, this is not an exhaustive list and any fact pattern that suggests a reasonable possibility of export regulation violation should be treated as a red flag (even if it is not on this list).

The Compliance Note also suggests using the consolidated screening list and the Treasury Department SDN list as compliance tools., “as well as conducting risk-based due diligence on customers, intermediaries, and counter-parties.”

https://www.aviationsuppliers.org/asa-afra-conferenceWe have seen increased reliance on end use and end user information to clarify where the parts are intended to be installed, as a means of protecting from unwanted diversion. I continue to work with companies on developing compliance systems to help ensure that the appropriate scrutiny is applied to export transactions. We will be leading export training classes during the ASA/AFRA Annual Conference as well as a discussion of tips and tools for export inquiries during the ASA Quality Committee meeting. I hope to see everyone at ASA’s 30th anniversary Annual Conference on June 4-6 in Orlando, FL!

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10 Boeing 777s Sold to Aeroflot (Be Wary)

January 24, 2023 by Leave a comment

Reuters is reporting that Aeroflot recently purchased 10 Boeing 777 aircraft that it previously had on lease.  They purchased the aircraft from the Irish lessor. 

What makes this transaction unusual? Aeroflot is subject to a Temporary Denial Order that would appear to make a transaction like this illegal (absent a US export license).

Boeing 777 aircraft are produced in the United States and are therefore subject to U.S. export and re-export standards.  The ownership of the aircraft does not matter to this assertion of jurisdiction over re-exports – so long as it remains an aircraft that was produced in the United States it is subject to U.S. export and re-export standards..

On April 12, 2022, the United States issued a Temporary Denial Order (TDO) affecting Aeroflot (the TDO was renewed in October).  Under that TDO, Aeroflot may not buy any item subject to the EAR (like an aircraft) that was previously exported from the United States.  In fact, the TDO also prevents them from even negotiating to acquire such an asset. Typically Aeroflot would also be forbidden from applying for licenses for transactions but there is an exception to this clause that permits them to apply for a BIS for transactions directly related to safety of flight.  So it is possible that the transaction was licensed by BIS, but the news articles we’ve been able to find do not provide this information.

There is a corollary provision in the TDO that also makes it illegal to facilitate acquisition by Aeroflot of ownership of items like aircraft.  This also permits a license to be issued for safety of flight transactions. This side of the restriction would seem to make the transaction illegal from the lessor’s point of view, as well (unless there was a license of license exception that applied to the transaction).

One news article asserts that the transaction is legal because of a provision in European law that permits such transactions.  This statement may not be 100% accurate because it fails to take into account the US laws that apply to the transaction.  This EU provision would not insulate the companies from compliance with U.S. export laws.  Again, we do not know if a license was sought from the U.S. government that would have permitted the transaction to be concluded in compliance with US BIS export provisions.

Last month, Reuters had reported that such talks were beginning, and a week later Reuters announced that Aeroflot had concluded the transaction.

The Reuters article suggests that the leasing company is a subsidiary of VEB. If this is true then there may be additional problems with the transaction, because VEB is a specially designated nation (SDN) under the OFAC sanctions programs. OFAC sanctions flow-down (apply) to entities that are 50% (or more) owned by an SDN.

ASA members should be careful around transactions like this. If you see others performing transactions like this, then do not assume that you can perform a transaction like this without restriction. On the other hand, bear in mind that identifying the applicable restrictions and obtaining the right government licenses can allow you to perform transactions that might otherwise seem “impossible.”

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No: The New Replacement Parts Exception Does Not Apply to Aviation

December 20, 2022 by Leave a comment

Tomorrow’s Federal Register is expected to include a new exception that permits export of replacement parts in a very broad range of circumstances. Don’t get too excited – it doesn’t apply to aviation.

The summary of the new exception reads like this:

“The Department of the Treasury’s Office of Foreign Assets Control (OFAC) is amending its regulations in multiple sanctions programs to add general licenses authorizing certain transactions of nongovernmental organizations and certain transactions related to the provision of agricultural commodities, medicine, medical devices, replacement parts and components, or software updates.”

federalregister.gov/d/2022-27639

But when you get into the regulatory language, it is clear that the replacement parts provision only applies to replacement parts for medical devices.

I did not want anyone from our community to see the title or the summary and think it applies to aviation.

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