The Bureau of Industry and Security (“BIS”) today added a number of entities to the Entity List, including Greek charter airline Sky Wings Airlines. When a company is added to the Entity List, all exports of items “subject to the EAR” — i.e. items with at least 25 percent U.S.-origin controlled content — will require export licenses before they can be exported to that company. Normally there is a general policy of denial for license applications for exports to companies on the Entity List, and that is the case for Sky Wings.

BIS stated the following reason for the designation:

Specifically, these persons were involved in the lease, transfer, and operation of commercial aircraft subject to the EAR, without the requisite licenses, for use in Syria and Iran.

The BIS designation does not provide any details to support this allegation, but they are not difficult to find. Sky Wings leased an MD-83 to Iran’s Zagros Airlines in January 2011.

As a result of being placed on the Entity List, Sky Wings will now find it difficult to obtain parts necessary to operate and service its aircraft, including those aircraft used to ferry European vacationers to Mediterranean beach resorts. Whatever one thinks of the damage that may or may not have occurred to the United States because an MD-83 was leased to an Iranian air carrier, that hardly seems a justification for taking actions that endanger passengers on all Sky Wing flights.

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