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U.S. BIS imposes $285,000 penalty to resolve violations of unlicensed reexports to Russia by Turkish aviation company

The penalty resolves alleged violations of the Export Control Reform Act of 2018.

June 13, 2024

The Bureau of Industry and Security (BIS) of the U.S. Department of Commerce today announced a $285,000 penalty imposed on an aviation company based in Ankara, Türkiye.

According to the BIS release, the penalty resolves alleged violations of the Export Control Reform Act of 2018, specifically concerning unlicensed reexports to Russia.

In October 2023 and January 2024, the aviation company conducted private charter flights using a U.S.-origin Gulfstream aircraft into Russia without the required BIS license. These flights were arranged by Russian nationals and facilitated through third-party non-Russian charter brokers. The flights did not qualify for the license exception under Aircraft, Vessels, and Spacecraft (AVS) because the flights were controlled by or under charter or lease by a Russian national.

For more information, contact a professional with KPMG’s Trade & Customs services:

Doug Zuvich
Partner and Global Practice Leader
E: dzuvich@kpmg.com
John L. McLoughlin
Principal and East Coast Leader
E: jlmcloughlin@kpmg.com
Andy Siciliano
Partner and National Practice Leader
E: asiciliano@kpmg.com
Steve Brotherton
Principal and Global Export and Sanctions Leader
E: sbrotherton@kpmg.com
Luis (Lou) Abad
Principal, Washington National Tax
E: labad@kpmg.com
Irina Vaysfeld
Principal
E: ivaysfeld@kpmg.com
Amie Ahanchian
Principal
E: aahanchian@kpmg.com
Christopher Young
Principal
E: christopheryoung@kpmg.com
Gisele Belotto
Principal
E: gbelotto@kpmg.com
George Zaharatos
Principal
E: gzaharatos@kpmg.com
Andy Doornaert
Managing Director
E: adoornaert@kpmg.com
Jessica Libby
Principal
E: jlibby@kpmg.com
John Anderson
Managing Director
E: johneanderson@kpmg.com
Jenna Leigh Glass
Managing Director
E: jennaleighglass@kpmg.com

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