International Trade Enforcement Roundup | March 2023


United States Obtains Warrant for Seizure of Airplane Owned by Russian Oil Company Valued at More Than $25 Million (DOJ Action)

Those involved. PJSC Rosneft Oil Company, a Russian energy company.

Charges and penalties. Violation of the Export Control Reform Act (ECRA) (seizure and forfeiture of the aircraft).

What happened? On March 8, the United States unsealed a warrant for the seizure of a Boeing 737-7JU aircraft after finding probable cause that the aircraft had been operated in violation of the Export Administration Regulations (EAR), the dual-use U.S. export controls regime. For more than a year, BIS has maintained strict controls on flying EAR-controlled aircraft into and out of Russia. BIS claimed that the aircraft in question had exited and reentered Russia at least seven times without a license.

The press release can be found here.

Notably. The U.S. government continues to target aircraft that have been operated in violation of U.S. export controls. In this case, with the issuance of a warrant, the U.S. government has taken the additional step of attempting to seize the aircraft.

Two U.S. Citizens Arrested for Illegally Exporting Technology to Russia (DOJ Action)

Those involved. Cyril Buyanovsky and Douglas Robertson, U.S. nationals.

Charges with penalties. One Count of Conspiracy to Commit Offenses against the United States (maximum of five years in prison); Four Counts of Unlawful Export of U.S.-Origin Controlled Goods to Russia (maximum of 20 years in prison for each count); Three Counts of Submitting False or Misleading Export Information (maximum five years in prison for each count); and Six Counts of Smuggling Goods from the United States (maximum of 10 years in prison for each count). What happened? On March 2, Buyanovsky and Robertson, owners and operators of KanRus Trading Company, were indicted for unauthorized exports of U.S.-origin avionics equipment to Russia and improperly providing Russian entities, including the Federal Security Services (FSB), with repair services. The indictment alleges the defendants intentionally misstated the true end-users, value, and ultimate destinations of controlled items, shipping them through third-party countries. Buyanovsky and Robertson used Armenia, Cyprus, Germany, and the United Arab Emirates (UAE) as transshipment points.

The press release can be found here. The indictment can be found here.

Notably. Matthew S. Axelrod, the Assistant Secretary for Export Enforcement at BIS, recently stated that the illegal export of sensitive technologies in violation of export control rules is at the “top of our list from an enforcement perspective.” This matter is a reminder that violations can lead to severe financial and criminal penalties, including substantial jail time.

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