Last week the Directorate of Defense Trade Controls (“DDTC”) posted a charging letter, a consent agreement, and an order relating to alleged export violations by Air Shunt, a California-based distributor of aircraft parts. Under the settlement, Air Shunt agreed to a $100,000 fine which was suspended provided that $70,000 had been spent on past compliance measures and $30,000 will be spent on future remedial actions specified in the consent agreement. Specifically, Air Shunt agreed to conduct an audit of its compliance procedures as well as to facilitate on-site inspections by DDTC with minimal advance notice.

The charges set forth in the charging letter consist of three exports which were previously recounted in an indictment filed against John Nakkashian, a former Vice-President of Shunt and a current fugitive from justice. These consisted of unlicensed exports of a J85-GE-21B engine actuator to the UAE, a J85-GE-21B engine ignition exciter to the UAE, and an Ametek military helicopter gyroscope to Thailand. The indictment alleged a fourth export of a Hamilton Sundstrand Generator Control to the UAE which is not recited in the charging letter but is undoubtedly referenced when that letter mentions “additional violations” that might have been charged but for Air Shunt’s adoption of remedial measures. A fourth count in the charging letter re-iterates a charge, previously set forth in a criminal information filed against Air Shunt that arose from Nakkashian having falsely marked export documents for the gyroscope export with “NLR” meaning “No License Required.” Air Shunt paid a $250,000 fine as part of a plea agreement in the criminal matter.

It doesn’t take much speculation to figure out why Nakkashian’s exports led to criminal charges. The J85-GE-21B engine is used on the F-5 Freedom Fighter. The largest fleet outside the United States is in Iran, having been sold to the Shah prior to the revolution. (Smaller fleets are flown by Ethiopia, Morocco, and Saudi Arabia). I seriously doubt any regular reader of this blog will object when I surmise that the F-5 engine parts exported to the UAE were on their way to neighboring Iran.

A DOJ press release states that Nakkashian disappeared during the investigation of Air Shunt. His surname is a common Armenian surname and that could provide at least one clue as to where he might be.

[Thanks to reader HB for pointing out the F-5 connection.]

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