U.S. DOJ Acts to Forfeit $1.55 Million Aircraft Landing Gear Bound for Russia

In a move to tighten enforcement on export controls, the U.S. Department of Justice (DOJ) has initiated forfeiture proceedings for a Boeing 737-800 landing gear valued at $1.55 million, recently detained at Miami International Airport. This action underscores ongoing efforts to curb illegal re-exportation of critical technology to Russia.

Complex International Transactions Unveiled

The landing gear, originally purchased by GQ Solution Elektronik Ekipman Limited Sirketi based in Istanbul, Turkey, was intended for re-export to a company in Kyrgyzstan, which has been implicated in servicing Russian entities with dual-use items. The U.S. Treasury’s Office of Foreign Assets Control (OFAC) had previously designated RM Design and Development (RMDD) as a Specially Designated National (SDN) due to its involvement in Russia's prohibited sectors, illustrating the complex network of intermediaries used to circumvent U.S. sanctions.

Details of the Forfeiture

The seizure on September 1, 2023, by U.S. Customs and Border Protection (CBP) marks a significant enforcement action, tied to broader U.S. policies aimed at preventing sensitive technologies from enhancing Russian military capabilities or infrastructure, especially in light of ongoing geopolitical tensions.

Certified Entities and Compliance Claims

HML Aviation, the Florida-based entity from which the gear was purchased, is noted for its compliance with both Federal Aviation Administration (FAA) and European Union Aviation Safety Agency (EASA) standards, though its involvement raises questions about oversight and due diligence in international trade of aviation parts.

Parallel Legal Actions

This case parallels another incident where two Russian nationals admitted to conspiracy under the Export Control Reform Act (ECRA), involving over $4.5 million in aircraft parts smuggled from the U.S. to Russia through Turkish intermediaries. This series of legal actions by the DOJ highlights the serious repercussions for entities and individuals attempting to undermine U.S. export laws.