BIS Denies Export Privileges for Miami Company, Two People for EAR Violations

A Miami-based company, its manager and its registered agent were denied export privileges for illegally exporting goods to Syria, the Bureau of Industry and Security said in Nov. 14 notices. Arash Caby, Ali Caby and their company, Arrowtronic, violated the Export Administration Regulations by illegally exporting aircraft parts and equipment to Syrian Arab Airlines, a Specially Designated Global Terrorist, BIS said.

Arrowtronic was denied export privileges for six years from the date of the Oct. 30 order. BIS also suspended export privileges for both Arash Caby and Ali Caby for four years with an additional two-year probationary period, BIS said. The two-year probation will be waived if they commit no other violations of the Export Control Reform Act.

BIS said Arash and Ali Caby worked with Marjan Caby in 2013 and 2014 to buy airplane parts from U.S. suppliers and ship them to Syria. To hide the exports, they provided “materially false or misleading documents and information” and arranged for payments of the exports to be made by third-party companies. The scheme allowed them to complete “multiple transactions” with Syrian Air and ship the parts to the airline’s transshipment point in Dubai, United Arab Emirates, BIS said.

Ali Caby managed the Bulgarian office of Arrowtronic, also known as AW-Tronics, and Arash Caby managed its Miami office, BIS said. Marjan was the company’s internal auditor. Each “exchanged numerous emails” with other company employees authorizing the exports to Syrian Air, the agency said. The emails contained “instructions that were designed to prevent U.S. law enforcement from detecting” the illegal exports, BIS said, “and to allow them to continue by changing the routing of exports from AW-Tronics/Arrowtronic’s Miami, Florida office.”