It remains important for aircraft parts exporters to check their customers against the U.S. government export databases.
In today’s Federal Register, restrictions were renewed against an individual and her companies for supporting an Iranian airline, Mahan Airways, that has been designated by the United States as a Global Terrorist.
- Gulnihal Yegane, Merkez Mah. Hasat Sok. No: 52/6, Sisli, Istanbul, Turkey;
- Trigron Lojistik Kargo Limited Sirketi, Yanibosna Merkez Mah., Degirmenbah[ccedil]e Cad. No. 11, Airport Hill Sitesi Blok D.6,
Bah[ccedil]elievler, Istanbul, Turkey; - Ufuk Avia Lojistik Limited Sirketi, Merkez Mah. Hasat Sok., No: 52/6, Sisli, Istanbul, Turkey;
- RA Havacilik Lojistik Ve Tasimacilik Ticaret Limited Sirketi, Yesilce Mah. Dalgic SK., 3/101 Kagithane, Istanbul, Turkey
According to the Federal Register, Ms. Yegane was originally one of 19 persons accused of procuring parts to support the operation of Mahan Airways in Iran. 78 FR 75,463 (Dec. 12, 2013). Mahan Airways is designated by the United States as a Specially Designated Global Terrorist. 77 FR 64,427 (Oct. 18, 2011). Most recently (in 2017), Ms. Yegane was accused of obtaining CFM-56 engines and gaskets and isolators used on Boeing aircraft for shipment to Iran. 83 FR 4897 (Feb. 2, 2018).
Aircraft parts distributors should be cautious in their business dealings to ensure that they are not supporting persons or entities members in violation of the law, and this includes forbidden business dealings with parties subject to export restrictions.
As we’ve discussed in our export classes, one efficient way to identify parties who might be subject to export restrictions is to search the consolidated screening list found online at https://www.export.gov/csl-search. The Consolidated Screening List is a list of parties for which the United States Government maintains restrictions on certain exports, reexports or transfers of items. The restrictions are drawn from eleven export screening lists published by the U.S. Departments of Commerce, State and the Treasury.
We recommend that you check your business partners with every transaction, because a previously “clean” partner could be added to the lists at any time. Linking your computer-based transactions system to the Consolidated Screening List is one way to automatically ensure that every transaction is scanned. If you choose to do this, then make sure that other parties who are not entered into the system, but who are nonetheless part of the transaction, are also checked by hand. You can link to the database using the Application Programming interface (API), which enables computers to freely access the CSL in an open, machine-readable format. From this API, any company can build a search engine to quickly find names, aliases, and other screening information. Developers can find more information about the API online at https://developer.export.gov/consolidated-screening-list.html.