We usually don’t post enforcement summaries. However, I wanted to insure everyone was aware that the United States government is really going after non-U.S. entities. Please see below. Note it is the Commerce Department not OFAC at Treasury Department.
The U.S. Commerce Department’s Bureau of Industry and Security (BIS) recently issued a temporary denial order revoking the export privileges of a British Virgin Islands-based company, Evans Meridians Ltd., because it was involved in a plan to ship two GE commercial aircraft engines to Iran without first obtaining the proper licenses. Illinois-based Adaero International Trade LLC shipped the engines to 3K Aviation in Turkey and 3K was planning on reexporting the engines to Pouya Air in Iran. In early January, BIS revoked the export privileges of these three companies and has now decided to take action against Evans Meridian because it was listed as a purchaser on documents related to the transaction and acted as owner of the engines at one point. The government also noted that following BIS’s initial action against the three companies, Evans Meridian made a payment to 3K despite the fact that the denial order against 3K was in force. The engines currently remain in 3K’s possession in Turkey so there is still a risk that further attempts will be made to get the items to Iran.
These companies (so-called denied companies) are now disallowed from playing any role in exporting controlled items, cannot apply for export licenses, cannot negotiate sales or shipments involving controlled items, and cannot benefit in any way from any transaction involving controlled items. Third parties are also barred from helping or working with these denied companies on transactions involving controlled items.