BIS, DOJ Target Russian Nationals for Illegal Aircraft Parts Exports to Russia

The Bureau of Industry and Security issued a temporary denial order this week against two Russian nationals, their Florida company, a Maldives business and a Russian airline for a scheme to illegally supply aviation parts to Russia. Oleg Sergeyevich Patsulya and Vasilii Sergeyevich Besedin used their Florida-based company MIC P&I to try to export to Russia more than $2 million worth of U.S. aircraft components, including Goodrich brake assemblies, in a procurement network that went through Intermodal Maldives and eventually to Russia’s JSC Smartavia Airlines.

Alongside BIS, DOJ charged Patsulya and Besedin with conspiracy to violate the Export Control Reform Act and conspiracy to commit international money laundering. Both carry maximum 20-year prison sentences.

The BIS and DOJ actions “demonstrate our resolve in impeding Russian attempts to circumvent our export controls,” Matt Axelrod, top export enforcement official at BIS, said in a statement. He said the agency will “aggressively use all of our criminal and administrative enforcement authorities, including the imposition of temporary denial orders,” to prevent Russia from importing goods that support its war in Ukraine.

BIS said the scheme started in mid-2022, when Patsulya began communicating with various Russian entities, including entities on the agency’s Denied Persons List, about supplying them with the plane parts, including wheels, tires and brakes from U.S. suppliers. Patsulya in June received a list of components from Smartavia that the airline “sought to obtain” and offered to supply Smartavia with two of the Goodrich brake assemblies units for $105,000 each. That same month, Besedin received an email from a U.S. parts supplier offering five of the units for sale, and Patsulya soon offered the units to Smartavia for $515,000 total, receiving a wire transfer from the airline days later.

BIS said the brake assemblies were classified under Export Control Classification Number 9A991.d and controlled for anti-terrorism reasons. Along with Smartavia, Patsulya also spoke with Rossiya Airlines and Pobeda Airlines, after both became subject to temporary denial orders, about selling them aircraft parts, BIS said.

The aircraft parts were routed through Intermodal Maldives, with the first shipments sent around May 2022. By October, the Maldives company had received about 212 shipments, most of which were plane parts, BIS said, and exported those products to Russia. Those exports included a shipment of aircraft parts to a Russian freight forwarder and a shipment of “lab equipment” to a Russian customer, even though none of Intermodal Maldives' “export control documents” showed that the items were destined to Russia, BIS said.

Another shipment to Intermodal Maldives that was destined for Russia contained a rotary actuator, which was controlled under the Export Administration Regulations as EAR99. Although EAR99 items generally don’t require a license, BIS said it had “reason to believe” that the rotary actuator and other EAR99 items sent by Intermodal Maldives required a license because they were subject to Russian industry sector sanctions.

BIS said it conducted an end-use check on Intermodal Maldives in February and discovered that the company is a “designated cargo sales agent” for PJSC Aeroflot, another Russian airline subject to a temporary denial order. The agency also said that four of the five Intermodal Maldives shipments it “inquired” about were sent to Russia, including one destined for Russia’s Pobeda Airlines and another for Russia’s UTair Aviation JSC, both also subject to temporary denial orders.

The agency in November detained a shipment to Intermodal Maldives containing two units of the Goodrich brake assemblies, which required an export license but didn’t have one. A BIS investigation revealed the brake assemblies were bought by MIC, and Besedin “personally traveled to a warehouse location to inspect the brakes.” Another shipment detained by BIS in January contained the Goodrich brake assemblies and was bought by Patsulya and Besedin, who initially told the vendor the brakes were destined for Intermodal Maldives but later changed the shipping information to list Turkey as the destination after Besedin “was alerted by a U.S. freight forwarder of issues with shipping to" Intermodal Maldives.

Patsulya and Besedin emailed BIS agents as recently as April 20 to try to retrieve their detained brake assemblies, telling BIS that they are “intended for use in Turkey,” BIS said.

BIS said both Patsulya and Besedin have “engaged in repeated attempts to procure U.S. origin commodities for Russian end users,” and when one attempt fails, they “will simply continue engaging other suppliers.” As of Feb. 28, Intermodal Maldives was listed as the ultimate or intermediate consignee on 248 exports worth more than $5.1 million.

The 180-day temporary denial order imposed on Patsulya, Besedin, MIC, Intermodal Maldives and Smartavia took effect May 16. The order blocks them from exporting goods subject to the EAR .