US Domestic third-party sales have little to no risk, right?

Suppose you are part of the sales, compliance, or logistics teams within a Precision Aerospace Products (PAP). In that case, there are no worries about shipping our products to third-party domestic sellers located in the United States, right?  After all, the products we are selling are staying in the U.S.    We are not exporting them outside our country’s borders.  That is the third-party’s headache now, should they decide to export.  Everything should be fine.  But is that really true?

The fact is there is a real and measurable risk with selling our products and services to third-party distributors domestically.  These risks should be acknowledged and recognized by the entire PAP organization from top to bottom.  There are numerous legal prosecutions with the DOJ, in which domestic distributors ended up violating many export laws, and selling goods, products, or technology to places like Iran, China, and Russia.

Take for instance, Golden Gate International LLC.  It seems like an innocuously named company, with Aiden Davidson, a manager/registered agent of the company.  However, the DOJ ended up indicting Hamed Aliabadi and the Babazedeh Trading Company because Aiden was actually Hamed and Golden Gate was really Babazedeh.  This company regularly shipped products that included motors, pumps, valves, and other items from Savannah, Georgia, to Turkey.   You may ask yourself, well Turkey isn’t a bad country and an ally of the United States, what is the problem?  Well, those motors, pumps, and valves were forwarded on from Turkey to Tehran, Iran.  This was an intricate scheme and shell game operated from within U.S. borders to illegally export these products to a major state sponsor of terror.  Special Agent in Charge William Higgins of the Department of Commerce, Office of Export Enforcement notes:

 “We will fully and aggressively enforce our nation’s restrictions on exports to Iran.  The controls on exports to Iran help apply maximum pressure on Iran to end its promotion of instability and terrorism worldwide.  The Office of Export Enforcement will continue to work with our Law Enforcement partners to stem illicit trade that threatens U.S. national security and undermines U.S. foreign policy.”

How should we ensure the third parties we deal with are on the up and up while not violating the export laws ourselves?

1. Run all customers and third-party sellers against the Consolidated Screening List (CSL) (link:

2. Inquire with customers on the ultimate end user and end use of our product.

3. Have each customer provide PAP with an Export Compliance Agreement or End User Statement (if an end user is identified by the customer).

4. Stay vigilant looking for “red flags.”

5. Contact Compliance Department should any questions arise during your conversations with customers.

Remember, it is paramount we do everything we can to prevent our products from ending up in the wrong hands, which could be detrimental to U.S. national security and the security of our military personnel deployed globally.  We do not want to turn on the television one day and see PPI or C&S stickers on a Iranian C-130, because the next thing we could expect is a knock from a special agent with the Department of Commerce.