BIS Denial Order Targets Florida Freight Forwarder, Others Exporting to Russia

Belarusian national Kirill Gordei -- who was charged in July with violating export controls (see 2407030024) -- and his company, Apelsin Logistics, has tried to export more than a million dollars' worth of items from the U.S. to Russia, BIS said, including by transshipping the items through Turkey and the United Arab Emirates and lying to other shippers and freight forwarders about the actual value and ultimate destination of the goods. The items include an Orbitrap Exploris GC 240 Mass Spectrometer classified under Export Control Classification Number 3A999.b and worth more than $600,000, an indictment shows.

The BIS order, released Feb. 6, revokes the export privileges for 180 days of Gordei and Apelsin Logistics; Uzbekistan-based Marakanda; Russia-based Alinda Chemical Trade Company; Turkey-based Element Uluslararasi Nakliyat Ve Lojistick Tic; UAE-based Astec Astronomy (also known as Dubai Silicon Oasis); and Serbia-based AvioChem. They will be unable to participate in any transactions subject to the Export Administration Regulations.

BIS said Gordei and his freight forwarding business exported the mass spectrometer around August 2023, more than a year after the U.S. imposed more stringent export controls against Russia for its invasion of Ukraine. Russia-based Alinda and Uzbekistan-based Marakanda worked with Gordei to buy the spectrometer, BIS said. Marakanda bought the item from a California-based company, and Gordei arranged the shipment using “falsified shipping documents” given to him by Alinda, BIS said.

Those documents included “false commercial invoices” that didn’t list the California company as the seller, and instead listed two “unrelated” U.S. companies as the sellers. Those documents also said the shipment was valued at about $47,000, according to Gordei’s indictment, and would be shipped to Element in Turkey instead of to Russia, BIS said. The agency noted that an Alinda employee “informed” Gordei that the false documents were needed because the item required an export license to be sent to Russia. Without a license, the Alinda employee said, it would be detained by CBP.

BIS said Gordei then “arranged the transhipment” of the spectrometer from Turkey to a consignee in Moscow, which had the same address as Alinda and was likely a front company for the Russian business. Gordei and his company, Apelsin, then “directed” another U.S.-based freight forwarder to file Electronic Export Information using the falsified documents, which incorrectly listed Marakanda in Uzbekistan as the ultimate consignee.

On Aug. 28, 2023, Element wrote in an email to Gordei that the mass spectrometer would be shipped from Turkey to Russia the following day, BIS said. The email included an air waybill for the item issued by a Russian airline, the agency said. BIS said customs data showed that the item was imported into Russia in September.

BIS said Gordei, Apelsin and Element also tried to illegally export other export-controlled items to Russia by transshipping them through third countries and “frequently” using falsified shipping documents. On one occasion in September 2023, BIS Office of Export Enforcement agents detained an ocean shipment bound for the UAE that contained three “consolidated shipments” of diesel engine parts and agriculture tractor parts. OEE agents found out that Gordei and Apelsin shipped the items through a separate freight forwarder and they were actually bound for a company in Moscow.

The items were designated as EAR99 but needed a license to go to Russia, BIS said.

OEE agents detained another shipment in March 2024 at the Port of Atlanta that included an antenna, coupling, valve, motor and gauge. BIS said Gordei and Apelsin used a Miami-based freight forwarder to ship the items, listing Turkey-based Element as the ultimate consignee and an “unrelated” U.S. company as the seller. BIS reached out to that U.S. company, which told BIS agents that it didn’t sell Gordei those items and that the shipping documents, including the commercial invoice, had been falsified. BIS said CBP agents seized the shipment “under suspicion of violations of export control laws.”

CBP detained another shipment in May 2024 that contained “fire detection harnesses,” which were controlled under ECCN 9A991 and which needed a license for Russia. The EEI listed Apelsin as the freight forwarder and Dubai-based Astec as the ultimate consignee.

A BIS investigation showed Astec had previously bought aircrafts parts from the U.S. for a person associated with Serbia-based AvioChem, a company sanctioned by the U.K. in 2023 for illegally shipping parts to Russia. BIS also said it discovered that Astec and AvioChem share ownership and that Astec has supplied S7 Engineering, an arm of Siberian Airlines, which is also subject to a BIS temporary denial order (see 2412090012). BIS also noted that the Treasury Department sanctioned S7 Engineering.

In total, BIS said it has investigated about $1.2 million worth of illegal exports to Russia involving Gordei, Apelsin and the entities named in the order. Most of the time Gordei and Apelsin use other freight forwarders to handle the exports, BIS said, which allows them to avoid being named on the EEI and “obfuscates” their export history.

“It is therefore OEE’s belief that Apelsin and Gordei are likely involved in violations of the EAR additional to those detailed herein,” BIS said.

Gordei was arrested last year and charged with conspiracy to commit offenses against the U.S., smuggling goods from the U.S. and illegally exporting a spectrometer. A status conference in Gordei's case at the U.S. District Court for the District of Massachusetts is scheduled for Feb. 11.