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Newsletter

TRADE SECURITY BULLETIN – APRIL 2025

Alert: Illegal Export of Aircraft Parts to Sanctioned Countries

Recent Industry Scandal Overview

Recently, the U.S. Department of Justice exposed a network involved in the illegal export of aircraft parts to Russia, in direct violation of international sanctions. Companies such as Flighttime Enterprises Inc. and associated individuals were charged with smuggling, document falsification, and money laundering. This case highlights serious risks for companies across the aviation supply chain.

Why This Matters to Your Business

Your company could be unknowingly exposed if clients, brokers, or logistics partners divert parts to restricted destinations.

Sanctions apply even when goods are routed through intermediary countries.

Penalties include fines, decertification, legal action, and reputational damage.

Engenno’s Recommended Safety Net

To protect your business, we recommend the following best practices:

Rigorously Verify End Users and Final Destinations

Always identify and confirm the end user of each shipment.

Require and validate end-use declarations with traceability tools.

Regularly Review Sanctions Lists

Stay up to date with the following official lists:

  • OFAC – SDN List
  • BIS Entity List
  • UN Sanctions List

Strengthen Your Contracts

Include clauses that prohibit re-export to sanctioned destinations.

Define clear penalties for diversion or false declarations

Train Your
Team

Provide regular training for sales, procurement, and logistics staff.

Ensure they understand the risks of indirect export violations

Conduct Preventive Audits

Consider a pre-audit of your export compliance process, especially if you have clients or shipments routed through high-risk transit hubs like Turkey, UAE, or Armenia.

How Engenno Can Support You

  • Supply chain compliance assessments
  • Client verification protocol review amd audit
  • Internal policy development aligned with ASA-100, ISO 9001, AS9120
  • Custom training sessions for your team

Interested in a private compliance review?

Email us at solbravo@engenno.com