Aircraft Lessors, Financers Face Risk Under US Export Controls, Law Firm Says
Although the Bureau of Industry and Security hasn’t yet announced any enforcement actions against lessors or financers of restricted Russian aircraft, those parties still face significant compliance risks, Katten said in an April 8 alert.
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In its first enforcement actions against Russia since announcing a series of new export restrictions, BIS last week suspended the export privileges of three Russian airlines for violating U.S. export controls against Russia (see 2204070012). Even though the denial orders targeted only Russian airlines, Katten said BIS may also penalize parties, including lessors and financers, if they continue transactions with aircraft with knowledge that an export violation has been committed or is about to occur.
“This points out the ongoing risk to lessors and financers of U.S.-content aircraft operated by Russian airlines,” the firm said. But Katten also said the “tone” of BIS’s first enforcement action indicated that the “focus” of the new export controls is on Russian nationals, “at least for the time being.”