A Turkish aviation operator was fined for ferrying passengers into and out of Russia on a US manufactured Gulfstream executive jet without the requisite export license. The Commerce Department (BIS) imposed a civil penalty of $285,000 against Sapphire Havacilik San Ltd. STI (Sapphire), an aviation company headquartered in Ankara, Türkiye, to resolve violations of the Export Control Reform Act of 2018 (ECRA).
Although the Russian national passengers provided payment to Sapphire through third-party non-Russian charter brokers, such flights into Russia—which were arranged for the benefit of the Russian national or nationals on board—were nevertheless controlled by or under charter or lease by a Russian national. As such, the relevant flights did not fall within license exception Aircraft, Vessels, and Spacecraft (AVS) and violated Section 764.2(a) of the ECRA.
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