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BIS Fines Company, Owner for Illegally Reexporting Jet to Russia

The Bureau of Industry and Security this week fined British Virgin Islands-based company Hallewell Ventures and its owner, Albert Avdolyan, $374,474 for violating sanctions against Russia. BIS said Hallewell illegally reexported a Bombardier Global 7500 jet from the Maldives to Russia without a license.

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The violations occurred after Avdolyan -- who's sanctioned by the EU, Canada, France and other nations -- used another one of his companies, GlobalOne Management Group, to buy the Bombardier aircraft on Feb. 3, 2022, for $73 million, BIS said. The aircraft then flew from the Maldives to Moscow on March 12, 2022, and remained in Russia for 25 days, BIS said, until it departed for Dubai.

BIS said the aircraft was subject to the Export Administration Regulations under export control classification number 9A991. That's because it used two “GE Passport turbofan engines” made in the U.S. and therefore contained more than 25% U.S.-origin goods, the agency said, making it subject to U.S. export license requirements under the EAR’s de minimis rule. BIS added that its new Russia-related license requirements for certain aircraft exports went into effect in February 2022, almost a month before the plane flew to Moscow.

The agency also said the aircraft wasn’t eligible for License Exception AVS (aircraft, vessels and spacecraft) because of the length of time it remained in Russia. That license exception can be used only for certain aircraft reexported under “temporary sojourn,” which BIS said is 14 consecutive days or less. Before those 14 days are up, License Exception AVS says the aircraft must depart “for a country to which it may be exported without a license.”

As part of a settlement agreement with BIS, Hallewell and Avdolyan admitted to committing one violation of the EAR. If they don’t pay the penalty within 30 days, BIS may suspend their export privileges for one year.