Cablegate: Extrancheck: Post-Shipment Verification: Flylal Technics,
DE RUEHMO #3558 3441228
ZNR UUUUU ZZH
P 091228Z DEC 08
FM AMEMBASSY MOSCOW
TO RUCPDOC/USDOC WASHDC PRIORITY
INFO RUEHC/SECSTATE WASHDC 1058
RHMFIUU/US CUSTOMS AND BORDER PROTECTION WASHINGTON DC
UNCLAS MOSCOW 003558
USDOC FOR 532/OEA/M.HAMMES/L.RITTER
USDOC FOR 3150/USFCS/OIO/CEENIS/MCOSTA
USDOC FOR 532/OEE/MO'BRIEN
E.O. 12958: N/A
TAGS: BEXP ETRD ETTC RS
SUBJECT: EXTRANCHECK: POST-SHIPMENT VERIFICATION: FLYLAL TECHNICS,
VILNIUS, LITHUANIA, LICENSE NO. NLR
REFTEL: USDOC 06831
1. Unauthorized disclosure of the information provided below is
prohibited by Section 12C of the Export Administration Act.
2. Reftel 1 requested a Post-shipment verification to determine the
legitimacy and reliability of the end-user, FLYLAL Technics,
Vilnius, Lithuania. The company is listed on BIS license
application: NLR as the ultimate consignee of one (1) civil aircraft
appliance, indicator assy-mach/airspeed, part no. 4039891-903,
serial no. 84050753. ECCN 7A994. Controlled for regional stability
(RS) and anti-terrorism (AT) reasons. The exporter is The Memphis
Group, 3900 Willow Lake Blvd, Memphis, TN 38118.
3. On December 4, 2008, Export Control Attach Peter Liston
conducted the requested post-shipment verification with FLYLAL
Technics, A Gustaicio 4, Vilnius, Lithuania. The export control
officer met with Paulius Kavaliauskas, Spare Parts Department
Director at his office.
4. FLYLAL Technics is an independent company that separated from
FLYLAL Airlines in August 2007. It is a privately held Lithuanian
owned company that has 265 employees.
5. FLYLAL Technics fits and services aircraft from Lithuania and
the other Baltic States, the European Union and Russia. FLYLAL
Technics conducts the required maintenance based upon miles flown on
the Boeing 737-300, 400 and 500 series aircraft, and Saab 2000 and
340 aircraft. FLYLAL Technics added the aircraft parts brokering
business to their operations in August 2008.
6. During discussions with Paulius Kavaliauskas, Spare Parts
Department, it was discovered that FLYLAL Technics does not have an
internal export compliance program to safeguard U.S. origin parts.
Kavaliauskas stated that he purchases parts for Russian companies
and that all of his suppliers know this and sell him the parts
anyway. ECO Liston could not corroborate this statement.
Kavaliauskas stated that he believes all aircraft parts brokers
operate the same way. Kavaliauskas stated that he receives between
20 and 50 inquiries a day for various parts and didnQt realize that
he had to know the End Use destination, or that he had to advise the
parts brokers and suppliers that he ordered from of the ultimate
destination of the particular part(s).
7. The commodity subject to this PSV was solicited to FLYLAL
Technics through an email inquiry from a Russian company by the name
of Techno Trade (firstname.lastname@example.org). Techno Trade requested a price
quote for the subject commodity. FLYLAL Technics contacted GE
Commercial Aviation Services in London, England for a price quote
for the part without ever advising GE that the ultimate destination
for the part is Russia. GE Commercial Aviation Services in London
obtained the part from a subsidiary in Memphis, TN and caused it to
be shipped NLR to Lithuania believing the part would remain in
Lithuania. FLYLAL Technics then invoiced the part to an off-shore
company in the British Virgin Islands by the name of Palmstone
Holdings Limited. The part was shipped to Techno Trade in Russia by
FLYLAL Technics. Payment was made through a bank transfer.
5. Recommendations: Post cannot/cannot recommend FLYLAL Technics, A
Gustaicio 4, Vilnius, Lithuania as reliable recipients of sensitive
U.S. origin commodities.