Civil Enforcement Information - Balli Group PLC and Balli Aviation, Ltd

Date issued: Feb. 10 2010

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TURBOFAC Commentary (800 words)

Notes:

1) At the time the violations were committed, Mahan Air was not an SDN designated pursuant to EO 13224.

2) For further factual information see Settlement Agreement - Balli Group PLC and Balli Aviation, Ltd. In addition to the indirect exports to Iran in violation of 560.204, the web post characterizes the violation of 560.203 as an "attempt," which in the Settlement Agreement is described as follows.

"During the period October 2006- July 2008, Balli Aviation and/or Balli Group appear to have violated § 560.203 of the ITR when they engaged in financing and sales negotiations with Mahan regarding three additional airliners."

Considering that Mahan Air was not an SDN at the time, such that activities with the airline could be...