WASHINGTON, D.C. – Today, Bureau of Industry and Security (BIS) Office of Export
Enforcement (OEE) Director John Sonderman issued an Administrative Charging Letter against
Russian oligarch Roman Abramovich, alleging violations of the Export Administration
Regulations (EAR) involving flights of two U.S. origin aircraft to Russia without the required
export licenses from BIS. These aircraft include a Boeing 787-8 Dreamliner (Tail Number P4-
BDL, Manufacturer Serial Number 37306), valued at approximately $350 million, and a
Gulfstream G650ER (Tail Number LX-RAY, Manufacturer Serial Number 6417), valued at
approximately $60 million.

“The Commerce Department has put in place unprecedented export controls in response to
Russia’s illegal war against Ukraine,” said Assistant Secretary of Commerce for Export
Enforcement Matthew S. Axelrod. “Today’s action, and our recent changes to make such
actions public when brought, provides notice to the world of our commitment to enforce those
controls aggressively in a transparent way, consistent with our commitment to the rule of law.”

“Russian oligarchs such as Abramovich will not be permitted to violate U.S. export regulations
without consequence,” said OEE Director John Sonderman. “Those that violate the expansive
export controls imposed on Russia will ultimately find themselves the target of investigations by
OEE Special Agents and our law enforcement partners. Today, we are bringing a whole of
government effort directed against Abramovich and his aircraft with two coordinated
enforcement actions – OEE’s Charging Letter and the U.S. Department of Justice seizure
warrants.”

As a result of the stringent export controls imposed by BIS in response to Russia’s invasion of
Ukraine, a BIS license or license exception is now required for the export or reexport, including
the temporary export or reexport, of most commercial and private aircraft to Russia.
Furthermore, any aircraft subject to the EAR that is registered in, owned or controlled by, or
under charter or lease by Russia or a national of Russia, is prohibited from using an EAR license
exception for flights to Russia, regardless of whether that Russian national also has dual
nationality.

As alleged in the Charging Letter, Roman Abramovich is a Russian national, who effectively
owned, controlled, chartered and/or leased these U.S.-origin aircraft, which were subject to a
license requirement and were also ineligible for any license exception. The Charging Letter sets
forth three violations by Abramovich for flights to Russia involving these aircraft without the
requisite BIS licenses. Specifically, the charges include two violations involving the Gulfstream
aircraft and one violation involving the Boeing aircraft. Under the Export Control Reform Act of
2018 (50 U.S.C. §§ 4801-4852), among possible administrative sanctions, administrative
monetary penalties can reach up to $328,121 per violation or twice the value of the transaction,
whichever is greater. Violators may also be subject to the denial of their export privileges. A
denial of export privileges prohibits a person from participating in any way in any transaction
subject to the EAR. Furthermore, it is unlawful for other businesses and individuals to participate
in any way in an export transaction subject to the EAR with a denied person. The full charging
letter is available online here.

Today’s announcement is the first of its kind under new regulations issued on June 2, 2022,
allowing BIS to make Charging Letters public when filed. In publicly announcing this Charging
Letter, BIS is ensuring that the exporting community and public writ large know who is allegedly
violating our regulations. It also incentivizes those who may be in violation to cease and
voluntarily self-disclose such violations.

Today’s coordinated enforcement actions against Abramovich are the result of a joint
investigation by OEE’s New York Field Office and the Federal Bureau of Investigation’s (FBI)
New York Field Office. In addition to the Charging Letter against Abramovich, BIS is working
closely with the U.S. Department of Justice, U.S. Attorney's Office for the Southern District of
New York, and the FBI, who jointly announced today the issuance of seizure warrants for both
the Boeing 787 and the Gulfstream G650ER involved in the alleged export violations at issue.
Additional information on those actions is available here.

BIS previously publicly identified both aircraft as being in likely violation of U.S. export
controls. This public identification occurred as part of an effort to prevent, absent U.S.
Government authorization, the continued use by Russia or Russian nationals of any aircraft
subject to the EAR that were flown to Russia without the requisite license. BIS continually
updates the public list of aircraft that have flown to Russia in apparent violation of the EAR.

Additional BIS resources on export controls implemented in response to Russia’s invasion of
Ukraine are available at:
https://bis.doc.gov/index.php/policy-guidance/country-guidance/Russia-b…

The public may submit confidential enforcement tips via the BIS website:
https://www.bis.doc.gov/index.php/component/rsform/form/14?task=forms.e…,
or by calling the Enforcement Hotline at 1-800-424-2980.

These BIS actions were taken under the authority of the Export Control Reform Act of 2018 and
its implementing regulations, the Export Administration Regulations (EAR).

For more information, visit www.bis.doc.gov.

A Charging Letter is merely the means by which administrative enforcement proceedings are
initiated pursuant to the EAR, and the respondent is entitled to contest the violations and
allegations therein, as part of the adjudicative procedures set forth in Part 766 of the
Regulations. Administrative enforcement proceedings under the EAR currently are adjudicated
by administrative law judges employed by the U.S. Coast Guard