Regarding a media report published in 2023 that mentioned our company in the context of alleged deliveries of aircraft spare parts to sanctioned destinations (and several subsequent reports from the same year that merely drew information from the original report without further independent verification), and given that this report may still be taken into account as part of standard compliance due diligence conducted by business partners, we consider it necessary to issue the following statement.
First and foremost, we would like to express our appreciation for the work of investigative journalists who focus on uncovering the circumvention of international sanctions. Sanctions regimes are an important instrument of the international community, and their circumvention represents a serious issue that deserves attention. Transparency in international trade involving sensitive goods, including aircraft components, is in the interest of the entire industry. In this particular case, however, neutral commercial facts were presented in a manner that may have led readers to incorrect conclusions regarding the activities of our company.
APRAM Aerospace s.r.o. has been active in the aircraft spare parts distribution market since 2012 and holds ISO 9001:2016 certification and is a member of the Aviation Suppliers Association (ASA). Our company has not been and is not included on the sanctions lists of the European Union, the United States of America, or any other relevant jurisdiction known to us, and it does not conduct business with partners where it has information, or even reasonable grounds for suspicion, that the goods are intended for sanctioned entities, prohibited end use, or impermissible re-export to the Russian Federation after February 2022. We therefore categorically reject any claim or implication that our company supplied aircraft parts in violation of these sanctions requirements following the introduction of sanctions in response to the Russian Federation’s invasion of Ukraine.
Our company has long conducted business with foreign partners in various regions of the world, assessing each transaction based on the nature of the transaction, available information about the business partner, and the declared end use and end user. The transactions referred to in the 2023 media reports were carried out in accordance with these procedures, standard contractual relationships, and proper commercial documentation. In the case of Cargoline, the entity was based in Kyrgyzstan and, according to the information available to us at the time of the relevant transactions, was not included on any sanctions lists. Sanctions against this entity were imposed by the United States only subsequently, in July 2023. At the time of the business relationship, APRAM Aerospace s.r.o. had no information or indications suggesting that the declared business purpose or end use, or the end user, was inaccurate, or that this partner would be sanctioned in the future.
Measures Adopted by the Company
Following changes in the international regulatory environment after February 2022, APRAM Aerospace s.r.o. further strengthened its internal compliance procedures. We conduct even more rigorous screening of business partners, assess transaction risk, require detailed end-use documentation where relevant given the nature of the transaction, and also require customer declarations regarding end use and the prohibition of unauthorized re-export. We have implemented an updated internal compliance program that includes regular employee training and documented procedures for customer verification.
In the event of any newly identified doubts regarding the actual end use, destination of the goods, or links between a business partner and sanctioned or high-risk entities, APRAM Aerospace s.r.o. is prepared to immediately suspend or terminate the business relationship, even at the cost of financial loss.
Publicly available sources may also contain automatically aggregated databases or trade-flow summaries that, in the overwhelming majority of cases, do not reflect the actual business activities of a specific company. APRAM Aerospace s.r.o. is therefore prepared to provide its business partners with the necessary cooperation and relevant information for the purposes of their internal compliance assessments.
Our objective is to provide services to legitimate customers in the aviation industry and to act in compliance with applicable laws, sanctions regulations, and the principles of responsible international trade, while building long-term relationships based on trust, transparency, and a responsible approach to international commerce.
We issue this statement for the purpose of placing previously published information into the proper context and ensuring full transparency toward our business partners, suppliers, and customers.