In one of the most significant enforcement actions involving the illicit export of aircraft components to Russia since the imposition of sweeping sanctions in response to the country’s invasion of Ukraine, the U.S. Department of Justice recently unsealed an indictment charging FlightTime Enterprises, Inc. (“FTE”) and three of its employees implicated in a complex scheme to circumvent U.S. export controls. The indictment, filed in the United States District Court for the Southern District of Ohio, outlines an extensive conspiracy by the Ohio-based supplier of aviation parts to evade the restrictions imposed under the Export Control Reform Act (“ECRA”) and the Export Administration Regulations (“EAR”), as well as federal anti-smuggling and money laundering statutes. At the heart of the allegations is the deliberate and systematic effort by FTE and its personnel to disguise the true destination and end users of aircraft parts, thereby facilitating their continued supply to Russian entities in direct violation of U.S. law.

According to the charging document, FTE—a Nevada-incorporated company with operations in Ohio and Florida—was initially established as a U.S. affiliate of a Russian aviation supply company. The Russian affiliate, identified in the indictment, has been one of the largest private suppliers of aviation components within Russia, creating an inherent compliance risk given the enhanced export restrictions on Russia’s aerospace sector imposed by the Bureau of Industry and Security (“BIS”) in 2022. Rather than adhering to these restrictions, FTE, under the leadership of its executives—including Pavel Iglin, Daniela Friery, and Marat Aysin—allegedly engaged in a systematic scheme to circumvent the prohibitions by falsifying shipping documents, misrepresenting end users, and routing shipments through intermediary countries such as the United Arab Emirates, South Korea, Armenia, and the Maldives.

The indictment details multiple instances in which FTE employees coordinated the shipment of controlled aircraft components—including receivers, low-pressure turbines, and auxiliary power units—without obtaining the requisite BIS licenses. For example, in early 2023, FTE exported three aircraft receivers that were explicitly classified under the EAR as controlled items requiring a license for shipment to Russia. Despite this, company officials allegedly directed employees to strip all references to the Russian end user from the shipping documentation and reroute the goods through intermediaries in third countries to disguise the ultimate destination. A similar pattern emerged in the procurement and export of a $741,000 low-pressure turbine, which was allegedly routed through Dubai and the Maldives before arriving in Moscow. In each instance, FTE personnel purportedly falsified Electronic Export Information (“EEI”) filings with the U.S. government, declaring the intermediary companies as the ultimate consignees while concealing the fact that the true end users were Russian entities subject to export prohibitions.

Beyond export control violations, the indictment further charges FTE and its executives with smuggling offenses under 18 U.S.C. § 554, highlighting the defendants’ efforts to fraudulently facilitate the illicit shipment of restricted goods in contravention of U.S. law. The government’s allegations suggest that FTE not only engaged in deceptive shipping practices but also took active steps to mislead U.S. suppliers into selling controlled aviation components under false pretenses. One striking example involved the company’s procurement of an auxiliary power unit (“APU”) from a U.S.-based supplier, where the seller initially expressed concerns about FTE’s Russian ownership. To allay these concerns, Aysin allegedly provided reassurances that FTE was a U.S. entity with no ties to restricted Russian parties. Subsequently, Iglin signed a false sanctions compliance certification, affirming that the APU would not be exported to Russia, only for the component to be funneled through intermediaries and ultimately delivered to a Russian airline. The brazenness of the scheme underscores the lengths to which FTE and its personnel were allegedly willing to go to continue servicing Russian aerospace clients despite the legal prohibitions.

Compounding the severity of the charges, the indictment also alleges that FTE and its co-conspirators engaged in a sophisticated money laundering scheme to conceal the financial flows associated with the unlawful exports. Prosecutors contend that the defendants structured payments through bank accounts in jurisdictions outside of Russia to obscure the source and destination of the funds, thereby facilitating continued illicit transactions. These alleged efforts to launder proceeds of the illegal export scheme form the basis of a conspiracy charge under 18 U.S.C. § 1956(h), which carries significant criminal penalties. If convicted, the defendants face the prospect of both substantial monetary forfeitures and lengthy prison sentences.

The unsealing of the indictment represents yet another stark warning from U.S. enforcement authorities regarding the consequences of evading Russia-related export controls. In the wake of the United States’s decision to enact expansive sanctions and export control measures targeting Russia’s industrial and defense sectors, BIS has adopted a stringent policy of denial for license applications concerning controlled items destined for Russia. Companies and individuals engaged in the international trade of dual-use goods must therefore exercise heightened diligence in their compliance programs, ensuring that robust screening mechanisms are in place to detect and prevent unlawful diversions. The charges against FTE serve as a sobering reminder that U.S. authorities remain vigilant in their enforcement of export control laws and will aggressively pursue those who seek to circumvent these measures through subterfuge and deception.