Saturday, January 11, 2014


Pouya Airlines (Iran)
In an unusual move, The US Department of Commerce foiled the delivery of two General Electric jet engines to Iran, through a blocking order, coupled with the assistance of the Government of Turkey. The tradecraft employed illustrates to what lengths the Iran sanctions evaders will go to deceive legitimate businesses.

Here's how it played out:

(1) An American company, Adaero International Trade LLC, of Rockford, Illinois*, the seller, shipped the engines to Istanbul, Turkey, to a local aviation consulting firm, 3K Aviation Consulting & Logistics.(Reportedly, 3K officials stated publicly, and erroneously, that the sale was not subject to sanctions, because it took place outside the United States. We call that compliance malpractice where i come from).

(2) The seller stated that the engines were going to Germany, to be sold to a US company there, International Aerospace Group, Inc. , of Miami, Florida, and that the actual end user was a Russian airline, located in Siberia.

(3) The Turkish company supplied bogus documents that purported to show that a sale had gone through, and that the engines had been shipped to Germany, sold to the American company; The seller relied upon them, in the ordinary course of business.

(4) In truth and in fact, the engines were still in Turkey, and an Iranian air cargo freighter , from Pouya Airlines, was scheduled to pick them up, and deliver them in Iran. Turkish authorities reportedly did not allow it to come into the country.

(5) When American authorities confronted the Illinois company about the incident, its officers insisted that their documents showed the engines to be in Germany. Which company or companies conspired to evade the sanctions; seller, buyer, or consulting company ?

What do we learn from this case ?

(1) That Iranian sanctions evaders will forge documents, fake transactions, and deceive legitimate parties involved, all the while scheming to achieve their illegal ends. 3K Aviation Consulting & Logistics should be sanctioned by OFAC. Whether its officers will be charged with a crime is not known.

(2) In the future, you would do well to avoid accepting any shipping documents at face value, especially when the equipment or merchandise being sold could constitute dual-use goods that could be  useful to Iran's WMD or ballistic missile programs. Iranian sanctions evaders are criminals; remember that.

(3) Notwithstanding Turkey's role in preventing this shipment, it is still apparently ground zero for Iran sanctions evasion activity. Examine carefully all large international trade transactions of your clients, where the end user is in Turkey.

(3) Iran will go to great lengths to acquire prohibited goods.; ensure that your clients are not engage in illegal trade, whether wittingly or unwittingly.
* a/k/a Adaero/Ilgin Engine Services; the Managing Director, who has also been banned from export for 180 days, is Recep Sadettin Ilgin, SA Turkish national, formerly with Turkish Airlines. His role in this matter is unclear.

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