On September 30, 2025, the Bureau of Industry and Security (“BIS”), U.S. Department of Commerce, announced an administrative settlement with Hallewell Ventures, Ltd. (“Hallewell”) and its beneficial owner, Russian businessman Albert Avdolyan, arising from an unauthorized reexport of a Bombardier Global 7500 aircraft to Russia in March 2022. The matter concludes with a $374,474 civil penalty, payable within thirty days of the order, and conditions attaching the validity of any export license or privilege to timely payment of the assessed penalty. BIS initiated the case under Section 764.2(a) of the Export Administration Regulations (“EAR”) for engaging in prohibited conduct contrary to restrictions imposed under Section 746.8 following Russia’s further invasion of Ukraine.
The charging documents establish that Avdolyan, through various British Virgin Islands corporate vehicles, purchased the aircraft—identified as Bombardier Global 7500, Serial Number 70092, Tail Number T7-7AA—for approximately $73 million in February 2022. The aircraft, subject to the EAR by virtue of containing more than 25 percent controlled U.S.-origin content, including two GE Passport turbofan engines classified under ECCN 9A991.c, was finalized in Hallewell’s name on February 3, 2022. Shortly thereafter, BIS’s Russia sanctions rules entered into force on February 24, 2022, requiring a license for the export or reexport to Russia of aircraft classified under ECCN 9A991, with all applications reviewed under a general policy of denial.
Despite the newly imposed license requirement, on March 12, 2022, the aircraft flew from Malé, Maldives to Moscow, Russia. Flight records reflect that the aircraft remained in Russia for twenty-five days, departing only on April 6, 2022, for Dubai, United Arab Emirates. Because the aircraft stayed in Russia for longer than fourteen consecutive days, it was ineligible for treatment under the temporary sojourn provisions of License Exception AVS. BIS determined that this conduct constituted a reexport to Russia without the requisite authorization, thereby violating Section 764.2(a) of the EAR.
The charging letter further notes that the reexport of Aircraft 70092 was not an isolated incident. Flight records document over seventy additional flights and maintenance operations following the March 2022 changes to Section 746.8. Under General Prohibition 10 of the EAR, any subsequent use of an aircraft in Russia after an unlicensed reexport constitutes a further violation. BIS emphasized that it continues to monitor the aircraft’s movement, including a recorded flight to Turkey as recently as November 20, 2024.
To resolve the matter, BIS and the respondents entered into a settlement agreement under Section 766.18(a) of the Regulations. Hallewell and Avdolyan admitted to the conduct described in the Proposed Charging Letter, acknowledging responsibility for the March 12, 2022 reexport. The final order imposes a civil penalty of $374,474 and provides that full and timely payment is a condition to the granting, restoration, or continuing validity of any export license, license exception, or related export privilege. Should the respondents fail to satisfy the payment obligation, BIS may impose denial of export privileges in addition to interest, penalty charges, and administrative fees under the Debt Collection Act.
This case highlights BIS’s strict enforcement of the Russia sanctions regime introduced in early 2022. The regulations imposed sweeping license requirements on aircraft, engines, and other high-technology items to Russia and Belarus, with a presumption of denial for all license applications. The Hallewell settlement underscores the consequences of non-compliance even where the reexport involved a privately owned aircraft rather than commercial shipments, and reflects BIS’s continuing scrutiny of aviation assets containing U.S.-origin content that transit Russian territory. For companies and individuals involved in global aviation transactions, the case demonstrates the continuing breadth of U.S. jurisdiction under the EAR and the significant penalties that attach to unauthorized reexports to Russia.
