WASHINGTON, D.C. – Today, Matthew S. Axelrod, Assistant Secretary for Export Enforcement at the U.S. Commerce Department’s Bureau of Industry and Security (BIS), issued a Temporary Denial Order (TDO) suspending the export privileges of Florida company MIC P&I, LLC, Russian airline Smartavia, freight forwarder Intermodal Maldives, and Oleg Patsulya and Vasilii Besedin, two Russian nationals residing in Florida, for diverting civilian aircraft parts to Russia. The TDO is available online here.

In a related action, the U.S. Department of Justice unsealed a four-count indictment in the District of Arizona charging Oleg Patsulya and Vasilii Besedin for conspiracy to violate the Export Control Reform Act and money laundering violations to benefit the Russian civilian aviation industry.

The coordinated enforcement actions are part of a series of actions announced today as part of the first wave of actions taken by the Disruptive Technology Strike Force, which is co-led by the Department of Commerce and the Department of Justice. The complete list of actions announced today is available here.

“Today’s coordinated actions demonstrate our resolve in impeding Russian attempts to circumvent our export controls to support their defense and civilian aircraft operations,” said Assistant Secretary Axelrod. “We will aggressively use all of our criminal and administrative enforcement authorities, including the imposition of temporary denial orders, to help prevent Putin from acquiring the material he needs to prosecute his unlawful and unprovoked invasion of Ukraine.”

TDOs are some of the most significant civil sanctions BIS can issue, cutting off not only the right to export items subject to the Export Administration Regulations (EAR) from the U.S. but also to receive or participate in exports from the United States or reexports of items subject to the EAR. The Assistant Secretary’s order denies all of the export privileges described in part 764 of the EAR, which include (but are not limited to) applying for, obtaining, or using any license, license exception, or export control document, or engaging in or benefitting from such transactions, to prevent imminent violations of the EAR. The order was issued for a renewable 180-day period.

As described in the TDO and alleged in the indictment, since at least September of 2022, Patsulya and Besedin collaborated with representatives of Smartavia Airlines, as well as Rossiya and Pobeda Airlines, to acquire U.S. origin aircraft parts and components in violation of U.S. export controls. Rossiya and Pobeda Airlines have been subject to TDOs since May and June of 2022, respectively. Patsulya and Besedin, through MIC P&I, LLC, attempted to deceive U.S. industry and government officials by claiming that the end user for their purchases was in Turkey rather than Russia, and then attempted to illicitly transship items through the Maldives. Patsulya specifically claimed to represent a group of companies that supplied U.S. aviation parts and electronics for various kinds of aircraft to civilian companies and affiliates of Russia’s Ministry of Defense. 

This investigation was conducted by the BIS Office of Export Enforcement’s Phoenix Field Office and Boston Field Office jointly with the Federal Bureau of Investigation.

As referenced above, today’s actions were coordinated through the Disruptive Technology Strike Force, an interagency law enforcement strike force co-led by the Departments of Justice and Commerce to target illicit actors, protect supply chains, and prevent critical technology from being acquired by authoritarian regimes and hostile nation-states. Under the leadership of the Assistant Secretary of Commerce for Export Enforcement and the Assistant Attorney General for National Security, the Strike Force leverages tools and authorities across the U.S. Government in order to enhance the criminal and administrative enforcement of export control laws. 

Authorities and Export Enforcement Contact:

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

BIS controls exports, reexports, and in-country transfers of dual-use commodities, technology, and software for reasons of national security, missile technology, nuclear non-proliferation, chemical and biological non- proliferation, crime control, and regional stability. Criminal and administrative sanctions can be imposed for violations of the EAR. For more information, please visit: https://www.bis.doc.gov/index.php/enforcement.

Report suspected export control violations through the BIS online tip portal.  You can also call the Enforcement Hotline at 1-800-424-2980 or email [email protected].

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