Case No. IA-2015-319421-1

Date issued: Mar. 16 2016

Last substantive commentary amendment:
Dec. 08 2023

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TURBOFAC Commentary (821 words)

Notes:

1) BACKGROUND

On Aug 13, 2015, BIS issued a civil penalty in the amount of $40,000 to the UAE entity Gatewick LLC, which BIS described as "freight and cargo services company in the UAE and at all times pertinent hereto the sole booking agent for air freight forwarding and cargo services for Mahan Airways, an Iranian airline". The $40,000 penalty arose out of transactions involving Mahan that, in addition to violating the EAR, also violated OFAC regulations. More specifically:

"Gatewick took actions that, contrary to the terms of a BIS denial order, facilitated the acquisition by Mahan Airways, an Iranian airline and a denied person since March 21, 2008, of the ownership, possession or control of approximately 2,300 computer motherboards, items subject to the [EAR] and valued...