BIS Issues, Renews Denial Order For Russian Export Control Evasion Network

The Bureau of Industry and Security last week suspended export privileges of Aratos Group, a collection of defense and technology companies in the Netherlands and Greece, and its owner for procuring goods for Russian intelligence services in violation of U.S. export controls. BIS also renewed a temporary denial order against three people and two companies also involved in a Russian sanctions evasion scheme.

A denial order now applies to Aratos Group and its leader, Nikolaos Bogonikolos, who BIS said runs a network of defense companies that falsified documents to evade U.S. export controls against Russia. Bogonikolos was indicted in May for illegally shipping dual-use technologies to Russia, including battlefield equipment, advanced electronics and “sophisticated” testing equipment (see 2305160086).

The agency added Bogonikolos and Aratos to an existing denial order for Boris Livshits, Svetlana Skvortsova and Aleksey Ippolitov, along with New York-based companies Advanced Web Services and Strandway, who were charged in December with conspiring to violate U.S. export controls by sending electronic signal generator and measurement equipment, along with other items, to Russian entities on the Entity List, including OOO Serniya Engineering (see 2212130050).

The denial order, which bans the people and companies from participating in transactions subject to the Export Administration Regulations, will remain in effect for 180 days from June 8 and may be renewed.

BIS said it renewed its denial order for Livshits, Skvortsova, Ippolitov and the New York companies after discovering that this “illicit network and its reach are broader in scope and more extensive than initially realized.” The agency said it learned that Bogonikolos is one of “multiple co-conspirators” involved in the network and was recruited as a procurement agent by Serniya.

Bogonikolos worked to hide multiple illegal shipments destined for Russia, BIS said, including by signing a “false end-use statement, stating that certain items were only for use in the Netherlands.” The agency also found that Bogonikolos and employees of the Aratos Group tracked orders for the Serniya on a spreadsheet, which listed the applicable Export Control Classification Number for certain items. One spreadsheet “included a column related to export controls and information about U.S. and European export control restrictions,” BIS said, “demonstrating knowledge and familiarity with export control laws.”

BIS said Livshits, Skvortsova and Ippolotov remain fugitives in Russia, adding that the agency has “reason to believe that their illicit procurement efforts will remain ongoing, given the length and nature of the conduct identified to date.” They are “familiar with methods of concealment and are likely to use increasingly sophisticated methods to avoid detection by law enforcement,” the agency said.