The OverRuled: BIS Export Controls Module has been updated with the following actions:
- 30 Sep 2025 - Hallewell Ventures, Ltd. and Albert Avdolyan - No Denial Order; USD $374,474
BIS issued an Order approving a settlement between BIS and Hallewell Ventures, Ltd. and Albert Avdolyan (the “Respondents”) in connection with violations of 15 C.F.R. § 764.2(a). Specifically, on or about March 12, 2022, Respondents reexported a Bombardier Global 7500 Aircraft from the Maldives to Russia without the required BIS license. The Bombardier Global 7500 Aircraft is subject to the Regulations because it contains two U.S.-manufactured GE Passport turbofan engines classified under ECCN 9A991.c. As part of the settlement and Order, Respondents were assessed a civil penalty of $374,474.00.
- 30 Sep 2025 - Luminultra Technologies Inc. - No Denial Order; USD $685,051
BIS issued an Order approving a settlement between BIS and Luminultra Technologies Inc. (the “Respondent”) in connection with violations of 15 C.F.R. §§ 764.2(e) and 764.2(g). Specifically, on or about October 1, 2022, Respondent exported to Iran three PhotonMaster luminometers and twenty-five aqueous test kits, all of which are categorized as EAR99 items that require authorization for export to Iran. The items were valued at $33,681.00. Additionally, on or about October 5, 2022, Respondent made false and misleading representations, statements, and certifications, in connection with the submission of an Electronic Export Information (“EEI”) filing. As part of the settlement and Order, Respondents were assessed a civil penalty of $685,051.00.
- 30 Sep 2025 - URAL Airlines JSC - Denial Order; No monetary penalty
BIS renewed against URAL Airlines JSC (“Respondent”) a Temporary Denial Order (“TDO”) originally issued on September 20, 2024 for a period of 1 year in relation to violations of the Export Administration Regulations (“EAR”). Specifically, Respondent operated multiple aircraft subject to the EAR and classified under ECCN 9A991.b on flights into Russia after March 2, 2022. Most recently, Respondent has continued to operate such aircraft on flights into and out of Russia after the September 20, 2024 TDO. BIS found that the continued operation of these aircraft by Respondent presents a high likelihood of imminent violations warranting renewal of the TDO.
The OverRuled: Russia Trade Controls Resource Center has been updated with the following actions:
- 30 Sep 2025 (BIS):
The Department of Justice (“DOJ”) announced that Oleg Chistyakov, a Latvian national and former broker for KanRus Trading Company Inc. ("KanRus"), pleaded guilty for his role in a years-long conspiracy to sell avionics equipment to Russian end users in violation of U.S. export controls.
- 30 Sep 2025 (BIS):
The U.S. Department of Justice (“DOJ”) announced that Bence Horvath, a dual citizen of Hungary and Spain and resident of the United Arab Emirates, was sentenced to 31 months in prison in connection with a scheme to unlawfully export military-grade radio communications technologies to Russian end-users without authorization. Horvath's sentencing follows his guilty plea on June 17, 2025, and his arrest on August 26, 2024.
- 30 Sep 2025 (BIS):
The Bureau of Industry (“BIS”) renewed its Temporary Denial Order (“TDO”) on Russian airline URAL Airlines JSC (“Ural”) for a period of one year.
- 29 Sep 2025 (BIS):
The Bureau of Industry and Security ("BIS") released an interim final rule (the "Affiliates Rule") that extends the license requirements that previously applied only to parties specifically listed on the Entity List and Military End User ("MEU") List to parties that are owned 50 percent or more, directly or indirectly, individually or in the aggregate, by parties listed on the Entity List or MEU List, or owned by parties that are subject to Entity List or MEU List restrictions by operation of this rule.
The Affiliates Rule makes similar changes with respect to transactions involving persons owned 50 percent or more, directly or indirectly, individually or in the aggregate, by Specially Designated Nationals and Blocked Persons ("SDNs") under certain OFAC sanctions programs.
The Affiliates Rule makes corresponding changes to the end-user scope of the Entity List foreign direct product ("FDP") rule and Russia/Belarus MEU FDP rule, and provided new red flag guidance.
Finally, the Affiliates Rule provides for a narrow 60-day Temporary General License ("TGL") for certain transactions, including exports to parties in A:5/6 countries, as well as procedures for impacted foreign entities to request for exclusion from the new license requirements.
The OverRuled: China Trade Controls Resource Center has been updated with the following actions:
- 29 Sep 2025 (BIS):
The Bureau of Industry and Security ("BIS") released an interim final rule (the "Affiliates Rule") that extends the license requirements that previously applied only to parties specifically listed on the Entity List and Military End User ("MEU") List to parties that are owned 50 percent or more, directly or indirectly, individually or in the aggregate, by parties listed on the Entity List or MEU List, or owned by parties that are subject to Entity List or MEU List restrictions by operation of this rule.
The Affiliates Rule makes similar changes with respect to transactions involving persons owned 50 percent or more, directly or indirectly, individually or in the aggregate, by Specially Designated Nationals and Blocked Persons ("SDNs") under certain OFAC sanctions programs.
The Affiliates Rule makes corresponding changes to the end-user scope of the Entity List foreign direct product ("FDP") rule and Russia/Belarus MEU FDP rule, and provided new red flag guidance.
Finally, the Affiliates Rule provides for a narrow 60-day Temporary General License ("TGL") for certain transactions, including exports to parties in A:5/6 countries, as well as procedures for impacted foreign entities to request for exclusion from the new license requirements.
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