BIS Fines, Revokes German Company's Export Privileges for Illegal Iran Shipments

The Bureau of Industry and Security denied export privileges for a German aircraft maintenance company and fined it more than $50,000 for procuring U.S. parts and components for a sanctioned Iranian airline. MSI Aircraft Maintenance Services International GmbH & Co. worked with Iran’s Mahan Airways (see 2011270001) to illegally export U.S.-origin reservoir and valve assemblies, which were controlled under the Export Administration Regulations, BIS said in a March 5 order. The agency said it will waive MSI’s three-year export denial if the company pays the fine, cooperates with BIS during a three-year probationary period and doesn’t commit any more EAR violations.

MSI worked to illegally export about $51,000 worth of U.S. parts to Mahan in 2011 and 2012, BIS said, adding that the items were also subject to Iranian Transactions Regulations under the Treasury’s Office of Foreign Assets Control. MSI never applied for a BIS or OFAC license and told a U.S. supplier of the goods they were destined for Thai and Afghan airlines.

BIS said MSI and another German company emailed Mahan Airways to say they were “preparing a big shipment” of parts “for you” and sent Mahan officials copies of three delivery notices, listing Mahan as the customer. The serial numbers on the notices matched the U.S. reservoir and valve assemblies the U.S. supplier had exported to MSI in Germany, BIS said. The agency said it found a waybill showing the goods then were exported from Germany to Tehran in July 2012 for delivery to Mahan officials.

If MSI doesn’t pay its fine within 30 days of the March 5 order, the company will face penalty charges and could be subject to the full three-year export denial order, BIS said. MSI agreed to cooperate with BIS during a three-year probationary period, including allowing BIS and OFAC access to documents related to the violations and other “potential violations.” MSI also said it will cooperate with BIS and OFAC’s interview and deposition requests.