Criminal Indictment for Sanctions Violations: Exporting Aircraft Parts to Venezuela

On Monday, the U.S. Justice Department announced a criminal indictment against six employees from two aircraft parts distributors for sanctions evasion.

The defendants are accused of a scheme to circumvent U.S. sanctions laws by exporting Honeywell Turbofan Engines, from the United States to Venezuela, where they were expected to be installed on aircraft operated by Petróleos de Venezuela, S.A. (PDVSA), the Venezuelan state-owned oil company. The Justice Department contends that the defendants concealed from their sources in the United States that the articles were destined for Venezuela and PDVSA. They did this by exporting the articles to the companies of the defendants: Novax Group S.A. and Aerofalcon S.L.

One of the defendants, George Clemente Semerene Quintero, was arrested on April 19, 2024, upon arrival at the Miami International Airport. He is PDVSA’s head of logistics, procurement and warehousing.

In November, The U.S. Bureau of Industry and Security added several companies to the Denied Entity List as a consequence of this same set of transactions, including:

• Aerofalcon S.L. (Spain);
• Novax Group S.A. (Costa Rica, Ecuador, Panama, Venezuela, and Russia); and
• Zero Waste Global S.A. (Panama and Venezuela)

According to the U.S. Government, all of these companies were added to the Entity List for circumventing U.S. sanctions, by exporting U.S. origin aircraft parts to Venezuela without proper licenses.

The Federal Register explains that the circumvention was accomplished by concealing the true end user and end destination of the exports using misrepresentations and fraudulent documents. These transactions also included the filing of false Electronic Export Information.