BIS Entity List: four entities for Venezuela aircraft-parts sanctions evasion and Russia IC diversion

Mechanism

This rule adds four entities across two distinct enforcement tracks:

Track 1 — Venezuela aircraft-parts sanctions evasion (Novax, Aerofalcon, Zero Waste)

Aerofalcon S.L. (Spain), Novax Group S.A. (with offices across Costa Rica, Ecuador, Panama, Russia, and Venezuela), and Zero Waste Global SA (Panama and Venezuela) acted as a multi-node transshipment network to procure and route US-origin aircraft parts to entities controlled by the Nicolás Maduro government in Venezuela. The scheme concealed the true end-user and end-destination by filing false Electronic Export Information and using fraudulent shipping documentation — a pattern typical of third-country aviation-parts diversion rings. Conviasa, the Venezuelan state airline, and 55 Venezuelan-registered aircraft already sit on OFAC's Specially Designated Nationals list, making any US-origin parts supply without a license unlawful. Novax's multi-country presence (five listings across four jurisdictions) illustrates how transnational structures fragment end-use traceability across jurisdictions with varying enforcement capacity.

Track 2 — Russia semiconductor diversion via India (Si2 Microsystems)

Si2 Microsystems Private Limited (India) was added for supplying Russian consignees connected to the Russian defense sector with US-origin integrated circuits after March 1, 2023 — the date on which BIS imposed broad Russia and Belarus controls under Section 746.5(a)(1)(ii) of the EAR (introduced via the February 2022 Russia/Belarus rules). This is a concrete instance of third-country IC diversion through South Asia, a route BIS had been tracking as a priority enforcement gap since mid-2022 when it began publishing guidance on known Russia-diversion transshipment hubs.

Downstream implications

• Novax's five-jurisdiction listing creates broad export-licence exposure for any party dealing

with the network across Latin America and the former Soviet space simultaneously.

• The Si2 Microsystems listing foreshadows the broader India-as-diversion-conduit enforcement

wave BIS pursued through 2024 (see 2024-11-01 and 2025-09-16 multi-entity rounds).

• Presumption-of-denial review policy means effectively no commercial path to supply listed

entities; any transaction requires a validated end-use certificate and extraordinary justification — in practice a de facto prohibition.

Open questions

• Whether related individuals (beneficial owners of Novax/Aerofalcon) faced parallel DOJ

prosecution — DOJ charged ten individuals in a PDVSA-linked sanctions evasion case in April 2024 that may relate to the same network.

• Whether Si2 Microsystems is the same entity subsequently referenced in Indian customs seizure

records for suspected dual-use IC re-exports to Russia.