The U.S. Department of Justice announced a criminal sentencing in a case involving the unlawful export of controlled aviation technology to Russia, underscoring the continued enforcement of U.S. sanctions and export controls targeting the Russian defense and aerospace sectors.

According to the Department of Justice National Security Division, Sanjay Kaushik, a 58-year-old resident of Delhi, India, was sentenced in federal court in Portland, Oregon, after pleading guilty to conspiring to export controlled aviation components and a navigation and flight-control system to Russian end users without the required U.S. export licenses.

The sentencing resulted in 30 months of imprisonment followed by 36 months of supervised release, reflecting the seriousness with which U.S. authorities treat export control violations involving sensitive dual-use technology. Details regarding the case are available through the DOJ export control enforcement announcements page: justice.gov

According to court filings, the defendant conspired with others to procure aerospace goods and technology from the United States under the false pretense that the items would be supplied to an Indian company.

In reality, the components were intended for Russian end users.

The exported items included aviation-related equipment and a navigation and flight-control system with both civilian and military applications.

Because such technology falls within the scope of the Export Administration Regulations (EAR) administered by the U.S. Department of Commerce’s Bureau of Industry and Security (BIS), exporting the items to Russia required government authorization that was never obtained.

The scheme involved classic export diversion tactics, including misrepresentations about the ultimate end user and attempts to route controlled technology through third-country intermediaries.

Such diversion networks have become a major enforcement priority for U.S. regulators as Russia increasingly relies on overseas procurement channels to acquire restricted technology following the imposition of sweeping export controls after the invasion of Ukraine.

Federal prosecutors emphasized that export enforcement actions serve a critical national security function by preventing sensitive U.S. technology from reaching foreign military or intelligence services.

The Justice Department has significantly expanded resources devoted to investigating export control violations in recent years, frequently coordinating with the Department of Commerce’s Office of Export Enforcement and other federal agencies responsible for sanctions and export control enforcement.

For companies involved in exporting aerospace components, electronics, or advanced technologies, the case serves as a reminder that export controls extend beyond direct shipments to sanctioned countries.

Transactions involving intermediaries, distributors, or resellers must also be scrutinized carefully to ensure that controlled items are not diverted to prohibited destinations.

Effective export compliance programs must therefore incorporate robust due diligence procedures capable of detecting suspicious procurement networks and identifying red flags associated with potential export diversion.

PRACTICAL COMPLIANCE RECOMMENDATIONS

• Strengthen end-user verification procedures. Companies exporting controlled technology should implement rigorous due diligence processes to verify the identity and legitimacy of end users.
• Monitor diversion red flags. Unusual shipping routes, unfamiliar intermediaries, or inconsistent documentation may indicate attempts to circumvent export controls.
• Confirm export classification of products. Accurate Export Control Classification Number (ECCN) determinations are essential for identifying licensing requirements under the Export Administration Regulations.
• Implement enhanced screening for Russia-related transactions. Even indirect exposure through intermediaries or distributors may create compliance risks.
• Provide regular employee training on export controls. Staff involved in sales, logistics, and procurement should understand export restrictions and escalation procedures for suspicious transactions.