United States Files Forfeiture Action Against $1.55 Million Aircraft Landing Gear

WASHINGTON - The Department of Justice today announced the filing of a forfeiture complaint against a set of aircraft landing gear for a Boeing 737-800 that was detained in September 2023 at Miami International Airport by U.S. Customs and Border Patrol. The gear was purchased for the benefit of a Kyrgyz Republic-based transhipper of dual-use items servicing the Russian Federation, in violation of U.S. economic sanctions.

The pleas were announced by U.S. Attorney Matthew M. Graves, Assistant Attorney General for National Security Matthew G. Olsen Homeland Security Investigations (HSI) Special Agent in Charge Ryan L Spradlin of the Denver Field Office, and Assistant Secretary of Commerce for Export Enforcement Matthew S. Axelrod with the Department of Commerce, Bureau of Industry and Security.

According to court documents, the landing gear had been sold in June 2023 by a Florida-based aircraft parts overhauler and reseller for $1.55 million to an intermediary in Istanbul, Turkiye, GQ Solution Electronic Ekipman Limited.

"This Office continues to use every tool it has to stop illegal transactions with Russian businesses," said U.S. Attorney Graves. "Today's complaint stops an attempted illegal transfer to the Russian Federations of parts for airplanes and seeks to permanently deprive both the Russian Federation and the company that tried to sell them of these goods."

Concurrent with today's action, the State Department announced new sanctions against entities engaged in Russia's technology sector, including GQ Solution Elektronik Limited in connection with the company's supplying of electronic components to Russia-based companies.

In July 2023, the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) designated LLC RM Design and Development (RMDD) as a Specially Designated National (SDN) for operating in the electronics sector of the Russian Federation economy. According to OFAC, RMDD was established in March 2022, less than one month following the Russian invasion of Ukraine. OFAC has described RMDD as a "prolific shipper of dual-use goods to Russia, including to firms that have supplied electronics to Russia-based defense companies." As a result of RMDD's designation as an SDN, all property and interests in property of RMDD that are in the United States are blocked.

On July 25, 2023, five days after being designated as an SDN by OFAC, RMDD sent an email asking HML Aviation to "switch [the purchase] fully to our partners GQ Solution." After the email, all mentions of RMDD were scrubbed from invoices for the landing gear.

On August 29, 2023, GQ Solution completed HML Aviation's End Use/End User Certification form. Among the items included in the form are statements that GQ Solution "will not export or re-export U.S. products, technology or software… to any restricted country unless otherwise authorized by the United States Government."

On September 1, 2023, U.S. Customs and Border Protection (CBP) alerted the shipper that it had detained the landing gear shipment at the airport in Miami.

This forfeiture action is a product of the U.S. government's coordinated effort to enforce U.S. sanctions and export controls against the Russian Federation following the invasion of Ukraine. The forfeiture complaint detailed here is merely an allegation. The burden to prove forfeitability in a forfeiture proceeding is upon the government.

The Homeland Security Investigations (HSI) Colorado Springs Field Office and the Department of Commerce, Bureau of Industry and Security are leading the larger investigation into Russian Federation attempts to avoid U.S. sanctions and export controls.

This case is being litigated by Assistant U.S. Attorneys Conor Mulroe and Rick Blaylock Jr., with the U.S. Attorney's Office for the District of Columbia, and Trial Attorney Sean Heiden of the National Security Division's Counterintelligence and Export Control Section.

This case was coordinated through the Justice Department's Task Force KleptoCapture, an interagency law enforcement task force dedicated to enforcing the sweeping sanctions, export controls, and economic countermeasures that the United States, along with its foreign allies and partners, has imposed in response to Russia's unprovoked military invasion of Ukraine. Announced by the Attorney General on March 2, 2022, and under the leadership of the Office of the Deputy Attorney General, the task force will continue to leverage all of the department's tools and authorities to combat efforts to evade or undermine the collective actions taken by the U.S. government in response to Russian military aggression.