The aircraft equivalent of a parts case, with the whole aircraft as the item.
What OFAC alleged
OFAC’s enforcement information for 5 February 2010 says Balli violated the Iranian Transactions Regulations when it exported three commercial airliners from the United States to Mahan Airlines in Iran, then tried to export three more. The company did not voluntarily disclose it. The release is short. It does not date the exports, say how the aircraft were routed or describe how the sales were structured, so this page does not either, and the period shown is the year of the settlement.
The settlement
Balli settled with OFAC and the Commerce Department’s Bureau of Industry and Security together for $15 million, with $2 million suspended and waived as long as Balli complies with the export rules. Balli Aviation also pleaded guilty to a two-count criminal information from the Justice Department and paid a $2 million criminal fine. It agreed to external audits by an unaffiliated expert, and accepted a five-year BIS denial order on export privileges that is suspended while it complies.
Why it is here
It is the early record on Mahan Air, the Iranian airline that appears again fifteen years later in the Fracht case, where an aircraft still blocked as Mahan’s property flew a charter under a new tail number. For the parts side of the same sector, see aviation parts procurement and the Fokker Services case.
What the record shows
- Whole aircraft were exported, not only parts. The release says three airliners, with three more attempted.
- A parallel criminal case. OFAC, BIS and the Justice Department all acted on the same conduct.