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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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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FAA Unapproved Parts Notice on TCAS Units

August 2, 2023 by Leave a comment

Today, the FAA issued Unapproved Parts Notice (2023-AAE-EHL-20221214-460) for certain Rockwell Collins Traffic Collision Avoidance System (TCAS) Transmitters/Receivers that were sold by Aviation Parts, LLC of Moscow, Russia. The FAA said that the parts were sold with counterfeit identification plates.
The known affected units are TTR-921 TCAS Transmitter/Receivers with part numbers shown in the table below:

Article NomenclatureArticle Number
TTR-921 TCAS Transmitter/Receiver822-1293-001
TTR-921 TCAS Transmitter/Receiver822-1293-002
TTR-921 TCAS Transmitter/Receiver822-1293-003
TTR-921 TCAS Transmitter/Receiver822-1293-033
TTR-921 TCAS Transmitter/Receiver822-1293-320
TTR-921 TCAS Transmitter/Receiver822-1293-321
TTR-921 TCAS Transmitter/Receiver822-1293-322
TTR-921 TCAS Transmitter/Receiver822-1293-332

The FAA refers to these as “counterfeit TCAS Transmitter/Receiver units.” The FAA explains that their Suspected Unapproved Parts (SUP) investigation began in December, 2021. The investigation revealed that Aviation Parts, LLC, located in Moscow, Russia, sold two TCAS Transmitter/Receivers part number 822-1293-033 (TTR-921) that were advertised as overhauled, when in fact they were inoperable.

Since the initial investigation, the FAA has received additional reports concerning TCAS units with counterfeit identification plates. The FAA reports that when tested, none of these TCAS
units were operable.

Based on these facts, the FAA has recommended that the industry examine its aircraft parts inventory for any of these TCAS articles that have been distributed by Aviation Parts, LLC of Moscow Russia. If such articles are found within an existing inventory, the FAA recommends that they be quarantined to prevent installation until a determination can be made regarding their eligibility for installation.

For more information, or to report the discovery of any of the above-referenced units, you can contact the FAA’s Special Emphasis Investigations Team (SEIT):

FAA Special Emphasis Investigations Team

10101 Hillwood Parkway, Suite 6S-500

Fort Worth, TX 76177

Telephone: (817) 222-4600

Email: kenneth.feist@faa.gov

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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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Many More Russian Aviation Companies Added to U.S. Sanctions List

October 4, 2022 by Leave a comment

Today, the U.S. Government published a list of 57 entities added to the BIS denied entities list. Most of the newly-listed entities are aviation-related.

Typically, you may not export to one of these entities unless you first obtain a license from BIS permitting you do perform the export. Don’t forget that the “Russia-rule,” also continues to prohibit most export transactions to Russia and Belarus (15 C.F.R. 746.8). But this addition expands the prohibition against these entities from being involved in U.S. export transactions.

Many of these entities were added because of diversion to the Russian military in violation of the U.S. Military End User (MEU) rules.

The rule became retroactively effective as of September 30, 2022. For items that were legally in transit on September 30th, there is a “savings clause” that permits them to continue on their way.

The list of newly-added companies can be found in the Federal Register at 87 F.R. 60064 (Oct. 4, 2022). The full list of BIS denied entities can be found as Supplement No. 4 to 15 C.F.R. Part 744. You can also search the consolidated screening list, which consolidates the data from several different U.S. government sanctions lists across several different federal agencies.

Here is the list of newly-added entities:

Crimea Region of Ukraine

• Subsidiary Sevastopol Naval Plant of Zvezdochka Shipyard.

Russia

• A. Lyulki Experimental-Design Bureau,
• A. Lyulki Science and Technology Center,
• AO Aviaagregat,
• Central Aerohydrodynamic Institute,
• Closed Joint Stock Company Turborus,
• Federal Autonomous Institution Central Institute of Engine-Building N.A. P.I. Baranov,
• Federal State Budgetary Institution of Science P.I. K.A. Valiev RAS of the Ministry of Science and Higher Education of Russia,
• Federal State Budgetary Institution National Research Center Institute n.a. NE Zhukovsky,
• Federal State Unitary Enterprise All-Russian Research Institute of Physical, Technical and Radio Engineering Measurements,
• Federal State Unitary Enterprise State Scientific-Research Institute for Aviation Systems,
• Federal Technical Regulation and Metrology Agency,
• Institute of Physics Named After P.N. Lebedev of the Russian Academy of Sciences,
• Institute of Solid-State Physics of the Russian Academy of Sciences,
• Joint Stock Company 121 Aviation Repair Plant,
• Joint Stock Company 123 Aviation Repair Plant,
• Joint Stock Company 218 Aviation Repair Plant,
• Joint Stock Company 360 Aviation Repair Plant,
• Joint Stock Company 514 Aviation Repair Plant,
• Joint Stock Company 766 UPTK,
• Joint Stock Company Aramil Aviation Repair Plant,
• Joint Stock Company Aviaremont,
• Joint Stock Company Flight Research Institute N.A. M.M. Gromov,
• Joint Stock Company Metallist Samara,
• Joint Stock Company Moscow Machinebuilding Enterprise named after V.V. Chernyshev,
• Joint Stock Company NII Steel,
• Joint Stock Company Remdizel,
• Joint Stock Company Special Industrial and Technical Base Zvezdochka,
• Joint Stock Company STAR,
• Joint Stock Company Votkinsk Machine Building Plant,
• Joint Stock Company Yaroslavl Radio Factory,
• Joint Stock Company Zlatoustovsky Machine Building Plant,
• Limited Liability Company Center for Specialized Production OSK Propulsion,
• Lytkarino Machine-Building Plant,
• Moscow Aviation Institute,
• Moscow Institute of Thermal Technology,
• National Research Center Kurchatov Institute,
• Omsk Motor-Manufacturing Design Bureau,
• Open Joint Stock Company 20 Aviation Repair Plant,
• Open Joint Stock Company 32 Repair Plant of Flight Support Equipment,
• Open Joint Stock Company 170 Flight Support Equipment Repair Plant,
• Open Joint Stock Company 275 Aviation Repair Plant,
• Open Joint Stock Company 308 Aviation Repair Plant,
• Open Joint Stock Company 322 Aviation Repair Plant,
• Open Joint Stock Company 325 Aviation Repair Plant,
• Open Joint Stock Company 680 Aircraft Repair Plant,
• Open Joint Stock Company 720 Special Flight Support Equipment Repair Plant,
• Open Joint Stock Company Volgograd Radio-Technical Equipment Plant,
• Public Joint Stock Company Agregat,
• Russian Institute of Radio Navigation and Time,
• Rzhanov Institute of Semiconductor Physics, Siberian Branch of Russian Academy of Sciences,
• Salute Gas Turbine Research and Production Center,
• Scientific-Production Association Vint of Zvezdochka Shipyard,
• Scientific Research Institute of Applied Acoustics,
• Siberian Scientific-Research Institute of Aviation N.A. S.A. Chaplygin,
• Software Research Institute, and
• Tula Arms Plant.

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New OFAC General License 40 for Aircraft Parts

June 30, 2022 by Leave a comment

On Tuesday, OFAC issued General License 40 authorizing certain Russian transactions that are necessary to ensure the safety of civil aviation.

This General License may permit some transactions that have been restricted under recent sanctions provisions. Remember that the General License 40 works to overcome OFAC sanctions, but it has no effect on BIS sanctions, like those under 15 C.F.R. 746.8. You must comply with both OFAC export regulations and also BIS export regulations for exporting civil aviation parts! But if you obtain a BIS license to perform an export transaction into Russia, then this General License might be particularly useful to you to address the related OFAC sanctions.

Here is a checklist for using this new General License:

  • Identify the customer/end user
  • There is a list of 17 named blocked parties in the Annex to General License 40. Your customer/end user must be a party that is listed in this Annex to General License 40 (this include both the list of 17 named entities, and also any party that is blocked because of ownership by one of the 17 named entities – a ‘flow-down sanction’).
  • Identify the target aircraft on which the aircraft part will be installed:
  • The aircraft must be registered in a jurisdiction other than Russia
  • The aircraft must be operated solely for civil aviation purposes
  • Consider the aircraft part you intend to export
  • The aircraft part must support safe civil aviation operations
  • Ensure that none of these exceptions apply (an exception could cause the license to be inapplicable to your transaction:
  • Transactions prohibited by Directive 2 under E.O. 14024 (Prohibitions Related to Certain Foreign Financial Institutions)
  • Transactions prohibited by Directive 4 under E.O. 14024 (Prohibitions Related to certain Russian governmental entities)
  • Any transactions otherwise prohibited by the Russian Harmful Foreign Activities
    Sanctions Regulations, 31 C.F.R. Part 587. This includes transactions with blocked persons who are not listed on the Annex of entities associated with General License 40.
  • Don’t forget to check compliance with other regulatory regimes, including compliance with BIS export administration regulations under 15 C.F.R. 746.8.

Because of the BIS restrictions on export transactions with Russia, the OFAC General License may be inadequate, alone, to permit certain transactions for civil aircraft parts exported to Russia. But when coupled with BIS license exceptions or licenses, this provision may be quite useful in permitting the industry to export aircraft parts to Russia in support of civil aviation flight safety.

Here is the list of blocked entities that are described in the Annex to General License 40:
(a) Public Joint Stock Company United Aircraft Corporation;
(b) Irkut Corporation Joint Stock Company;
(c) Energotsentr Irkut;
(d) Irkut-Avtotrans;
(e) Irkut-Remstroi;
(f) Irkut-Stanko Service;
(g) Rapart Servisez;
(h) Sportivno-Ozdorovitelnyi Tsentr Irkut-Zenit;
(i) Tipografiya Irkut;
(j) Joint Stock Company Ilyushin Finance Company;
(k) Open Joint Stock Company Ilyushin Aviation Complex;
(l) Public Joint Stock Company Taganrog Aviation Scientific-Technical Complex N.A. G.M. Beriev;
(m) Joint Stock Company Flight Research Institute N.A. M.M. Gromov;
(n) Tupolev Public Joint Stock Company;
(o) Limited Liability Company Kapo-Avtotrans;
(p) Limited Liability Company Kapo-Zhilbitservis;
(q) Limited Liability Company Networking Company Irkut; or
(r) Any entity in which one or more of the above persons own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest.

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New Import Tariffs for Aircraft Parts from Belarus or Russia

June 30, 2022 by Leave a comment

Very little is being imported from Russia these days, but if you are importing Russian aviation products then you need to be aware of the unusual tariff treatment of those goods.

There is a “column two” in the harmonized tariff system of the United States. Column two is used for nations with whom the United States does not have normal trade relations (currently Cuba, North Korea, Russia and Belarus). Column two imposes much higher import duties. In April, Congress (P.L. 117-110 § 3(a) (April 8, 2022)) determined that column two would apply to products of Belarus and Russia. This means that aircraft parts from these two jurisdictions lose their duty-free status.

In today’s Federal Register, the President proclaimed a change in the column two duties that apply to many products from Russia, including certain aviation products and parts. This does not (yet) apply to Belarus. In essence for any affected goods, the 35% duty replaces whatever duty was normally established in column two.

For example, imagine you are importing a unit load device that is a product of Russia. It falls under tariff code 8609.00.00.00, which is for containers. As a container, it would have been subject to free (zero duty) entry under column one, but it would have been subject to a 25% duty under column two.

But under the new tariff rules, the same container will be subject to a 35% duty if it is imported from Russia.

Many aircraft parts under heading 8807 will be affected by this new rule (including those under 8807.10.00, 8807.20.00, 8807.30.00 and 8807.90.90. These new tariff rules apply only to Russia (not Belarus) and they go into effect on July 27, 2022.

For a complete list of the affected products, as well as full details on this new provisions, review the Presidential Proclamation in the Federal Register.

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BIS Expands Sanctions Against Russia and Belarus

April 15, 2022 by Leave a comment

Yesterday, BIS announced its latest round of sanctions against Russia and Belarus arising from Russia’s invasion of Ukraine. We have written about previous BIS sanctions against Russia and Belarus over the past several weeks. The previous rounds of sanctions imposed, among other things, a license requirement for all articles controlled under CCL categories 3 through 9 under a new § 746.8 of the EAR.

The latest sanctions expand that license requirement under § 746.8 to now include CCL categories 0 through 2 as well. Thus, any item specified under any ECCN is subject to an export license requirement. Although this may not seem like a broad expansion of the licensing requirements as far as aircraft parts distribution is concerned, it is important to note that many bearings are controlled under CCL 2 and certain seals, gaskets, sealants and fuel bladders specially designed for aircraft or aerospace are controlled under CCL 1. These items now require a license to Russia or Belarus.

The sanctions also further limit the availability of License Exception AVS paragraphs (a) and (b) to aircraft registered in, owned or controlled by, or under charter or lease by Belarus or a national of Belarus (bringing it in line with limitations on the exception already applicable to Russia and Russian nationals). We can therefore not rely on License Exception AVS–a commonly used license exception–to support a Russian or Belarusian aircraft.

The United States continues to impose additional sanctions as a result of the war in Ukraine. We will keep members updated as new sanctions that affect distributors arise.

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Russia-Sanctions Aimed at Aviation Businesses

March 9, 2022 by Leave a comment

Today, the Bureau of Industry and Security (BIS) published its new additions to the sanctioned entities list. Note that even though it was published today (March 9), it is effective as of March 3, 2022! We reported on this last week, so you should have had a little notice. That list includes aviation as one of the target industries.

Tomorrow, the Federal Register is scheduled to print new Treasury Department Sanctions against Russia. These sanctions include an A340-300 aircraft (MSN 955; registry # M-IABU). Other sanctioned aircraft include a Gulfstream G650 (MSN 6207; registry LX-MOW).

Last week, the Treasury Department Office of Foreign Asset Control (OFAC) updated their lists of Specially Designated Nationals to include aviation maintenance facilities, like JSC 558 Aircraft Repair Plant and airlines, like JSC Transaviaexport Airlines. Both of these companies are in Belarus. OFAC also added SDNs that have not yet been published in the Federal Register – these companies are listed in the SDN list, so they will appear in the government’s consolidated screening list; however the announcement was made in an OFAC press release rather than a Federal Register notice (these are just highlights):

  • ALTITUDE X3 LTD
  • AVANFORT OOO
  • AVIASTAR-SP AIRCRAFT MANUFACTURING ENTERPRISE
  • IRKUTSK AVIATION PLANT
  • IZHMASH-UNMANNED SYSTEMS COMPANY
  • JSC NOVOSIBIRSK AIRCRAFT PRODUCTION ASSOCIATION PLANT
  • KOMSOMOLSK-ON-AMUR AVIATION PLANT
  • ALL-RUSSIAN SCIENTIFIC RESEARCH INSTITUTE OF AVIATION MATERIALS

Remember, if you have property that belongs to any person or entity that has been blocked under the new OFAC Russian sanctions (pursuant to Executive Orders 14024 and 14065), then that property is blocked. The fact that the property is blocked means it may not be transferred, paid, exported, withdrawn, or otherwise dealt in under U.S. law. If, for example, you are managing a U.S. repair for a Russian business who gets added to the OFAC list of Specially Designated Nationals (under the authority of the Executive Order), then you may not return the part to the sanctioned party, nor may you participate in a work-around designed to circumvent the sanctions.

For most members of the ASA community, the BIS prohibitions on unlicensed exports to Russia will put a stop to unlicensed export transactions. But even if you get a BIS license, if your business partner is on the SDN list or is otherwise subject to the limitations of the Russia-related and Ukraine-related Executive Orders then you may also need a license from OFAC, as well.

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More Russia Sanctions Highlight the Importance of the Consolidated Screening List

March 4, 2022 by 1 Comment

The Bureau of Industry and Security (BIS) will be publishing a new list of Russia-sanctions targets next week. This list includes aerospace companies outside of Russia! This highlights the importance of checking your export business partners against the consolidated screening list for EVERY transaction.

Here is just a small portion of the companies that are being added to the sanctions lists, to show you that aerospace is part of the sanctions plan:

  • State Governmental Scientific Testing Area of Aircraft Systems (GkNIPAS)
  • Federal State Enterprise State Research and Testing Ground for Aviation Systems named after L.K. Safronov
  • Incoff Aerospace S.R.O.
  • Russian Space Systems (RKS)

There are also numerous research and development facilities that have been added to the BIS restricted lists. In all of these cases, there is a presumption of denial on license applications.

In addition, it appears that ship-building, oil & gas, and telecommunications industries are also being targeted in this latest round of sanctions.

The new sanctioned entities are expected to be published in the Federal Register on March 9; however the sanctions will relate back to the first date on which they were made ‘available’ to the public. They were placed on-line late last night so expect the sanctions to apply as of March 3, 2022!

We strongly recommend checking your business partners against the consolidated screening list for EVERY export transaction. Even if you checked them for a transaction yesterday, you should check them again today to make sure that they remain clear for today’s transaction.

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