Eleview settlement highlights US enforcement of export control rules on Russia

Eleview International Inc. (Eleview), a freight forwarding business based in Virginia; its owner and chief executive officer (CEO), Oleg Nayandin; and an employee, Vitaliy Borisenko, pled guilty on October 28, 2025 to conspiracy to violate the Export Control Reform Act (ECRA). The plea relates to schemes to transship more than USD6 million worth of sensitive United States technology to Russia through third countries and to provide false information on export control documentation submitted to the US government.

In parallel, Eleview entered into an administrative settlement with the Department of Commerce’s Bureau of Industry and Security (BIS), admitting to violations of the Export Administration Regulations (EAR).

This coordinated criminal and civil resolution follows November 2024 criminal charges brought by the Eastern District of Virginia covering the same conduct, as well as the Cadence Design Systems resolution, where the Department of Justice (DOJ) and BIS pursued a similarly coordinated enforcement action for unlawful exports of advanced semiconductor technologies to Chinese military-linked entities.

Together, these enforcement actions against Cadence and Eleview underscore the US government’s stated priorities to investigate and enforce against conduct that threatens US national security and economic interests, with particular emphasis on the unlawful transfer of sensitive items to nation-state adversaries through third countries to evade sanctions and export controls. The Eleview resolution also serves as a case study in cargo risk detection and control, illustrating how data trails, inaccurate documentation, and routing of shipments through third countries can raise compliance challenges and enforcement risks.

This alert explores the Eleview resolution, its alignment with DOJ and BIS enforcement priorities, and key lessons for companies – particularly those in the maritime and transportation sectors – navigating heightened regulatory scrutiny.

Summary of conduct and settlement terms

Eleview, Nayandin, and Borisenko conspired to violate the ECRA, 50 U.S.C. 4819(a)(1), (a)(2)(f), and the EAR, 15 C.F.R. Parts 730-774, by exporting and causing the export, re-export, and in-country transfer of items subject to the EAR to Russia without required licenses, and by making false statements and concealing material facts in export control documents.

From approximately February 2022 through June 2023, Eleview operated a freight consolidation and forwarding business from Chantilly, Virginia, which included a website that enabled Russian customers to purchase US goods for shipment to Russia directly or via third countries.

Eleview used three routes to transship US-controlled products to Russia while masking the ultimate Russian end users and destinations from US authorities, despite direct outreach from BIS Special Agents to Eleview in March 2022 regarding new export control restrictions involving Russia. The relevant activity included:

1. Shipments through a Turkish company acting as a diverter for a major Russian telecommunications company. Eleview exported about USD1.3 million worth of telecommunications equipment across 23 shipments to a locomotive company in Turkey, while ignoring red flags indicating the Turkish firm was acting as a transhipper for a major Russian telecommunications company – a longstanding Eleview client and supplier to Russia’s Federal Security Service. Eleview and its personnel repeatedly identified to US authorities in export documentation that Turkey was the ultimate destination and the Turkish firm was the ultimate consignee, despite knowing that the equipment was intended for a Russian telecommunications company and the Russian government. These actions caused Eleview to submit false filings to the US government, which were intended to disguise shipments that were ultimately destined for Russia and required BIS licenses.
   
   
2. Shipments to a Finnish freight forwarder feeding the Russian postal system, with concealed Russian labels and spreadsheets identifying ultimate customers in Russia. Eleview exported pallets of goods and electronic components worth more than USD3.4 million to a freight forwarder in Finland that facilitated subsequent transfers of the products via the Russian postal service to the ultimate Russian customer. As part of this operation, Eleview knowingly misidentified the Finnish forwarder and Finland as the ultimate consignee and destination on US export control documentation. In particular, Eleview affixed Russian postal service tracking numbers to the goods – but obscured by the pallet coverings – to facilitate subsequent shipping to their end destinations within Russia. Some of the 82 shipments included goods that required BIS licenses for export to Russia.
   
   
3. Exports to a Kazakhstan shipper that advertised delivery to the Commonwealth of Independent States (CIS) countries, including Russia. Export documents submitted by Eleview to US authorities for 52 shipments falsely listed Kazakhstan and the Kazakh shipping company as the final destination and ultimate consignee, respectively, even though Eleview knew the items – including about USD1.5 million worth of goods and controlled dual-use items like electronic test instruments (oscilloscopes) subject to the EAR and classified under Export Control Classification Number (ECCN) 3A992. – were destined for end users in Russia. They did not obtain the required BIS licenses.

Across these schemes, Eleview caused multiple false statements to US authorities in Shippers’ Letters of Instruction, invoices, Electronic Export Information (EEI) filings, and end-use certificates submitted to BIS Special Agents, all of which contained false or misleading information intended to reduce export scrutiny and avoid detection of the shipments’ ultimate Russian destinations and end users. These false or misleading statements continued despite BIS Special Agents conducting outreach visits and providing written guidance to Eleview on export compliance topics spanning red flags, reporting, screening, know-your-customer (KYC), recordkeeping, and general prohibitions. Eleview and its executives admitted to exporting restricted telecommunications and other items to Russia without required licenses following the Russia sanctions controls effective February 24, 2022.

Plea and resolution

Under the criminal resolution with the DOJ National Security Division and the US Attorney’s Office for the Eastern District of Virginia, Eleview, Nayandin, and Borisenko each agreed to plead guilty to one count of conspiracy to violate the ECRA. Eleview agreed to pay a USD125,000 criminal fine (reduced from USD600,000 based on an ability to pay analysis) and to serve a three-year term of probation, during which Eleview must complete export compliance training for its officers within three months and provide certifications of completion semi-annually. As part of this resolution, Eleview did not receive voluntary disclosure or cooperation credit.

Under the administrative resolution with BIS, Eleview, Nayandin, and Borisenko admitted to violations of the EAR and consented to a USD125,000 civil penalty (suspended and dollar for dollar credited against the DOJ fine), as well as mandatory export compliance training within three months and annually for three years. In addition, the company and individuals received a three year suspended denial of export privileges, suspended during the three-year probationary period, provided that Eleview and its personnel 1) comply with the civil penalty, 2) comply with the training requirements outlined in the BIS settlement, 3) comply with the terms of the DOJ plea agreements, and 4) do not commit additional violations of the EAR or ECRA.

Alignment with DOJ and BIS enforcement priorities

The Eleview case reflects the US government’s continued emphasis on aggressive, coordinated enforcement of sanctions and export control laws – particularly when intermediaries in the logistics chain facilitate evasion schemes that threaten national security. The resolution aligns with the DOJ Criminal Division’s May 2025 White Collar Enforcement Plan, which promised to prioritize investigations involving ten “high-impact areas,” including, among others:

• Trade and customs fraud
• Conduct that threatens the country’s broader national security priorities, including the prosecution of conduct that undermines US interests through the use of transshipment points.

These enforcement priorities have also been reiterated through DOJ’s August 29, 2025 announcement of its new Trade Fraud Task Force, a collaboration between DOJ’s civil and criminal divisions and the US Department of Homeland Security intended to bolster enforcement resources against customs fraud, smuggling schemes, and tariff evasion.

Eleview: A case study in cargo risk detection and control

The Eleview resolution also demonstrates how US authorities operationalize the principles outlined in the December 2023 joint compliance note from the DOJ, BIS, the Department of Homeland Security’s Homeland Security Investigations, the Department of State’s Directorate of Defense Trade Controls, and the Department of the Treasury’s Office of Foreign Assets Control. Specifically, the Eleview resolution underscores that:

1. Transshipment through third countries is a core red flag. The note flags abnormal routing and transshipment through third countries as a key evasion tactic. Eleview routed US items to Russia via Turkey, Finland, and Kazakhstan while masking the true end users and destinations. Freight forwarders and other entities involved in the transportation industries may consider enhancing their compliance programs to treat indirect routings to high risk jurisdictions as an elevated risk requiring enhanced scrutiny, corroboration of end users, and escalation.
   
   
2. Lower tech items may pose a high risk where the technology is misused by adversary nations. The note cautions that risk is cargo specific and does not only include “sensitive” items, because lower-risk items are still a national security threat when destined for or linked to prohibited end users or destinations. In Eleview, the Russia destination elevated the risk profile and triggered license requirements that the company ignored, even after being warned repeatedly by BIS agents. Recent rules further sharpen this point: license applications for these ECCNs involving military end users or military end uses in China or Russia, among other countries, are subject to a presumption of denial, and, for Russia, all Commerce Control List items and a variety of EAR99 items require a license or license exception, subject to a policy of denial. Shipping companies may consider treating these categories as high risk when China, Russia, or one of their affiliated countries is implicated and conduct end use diligence and certifications accordingly.
   
   
3. KYC must extend to the real end user. Beyond screening the immediate consignee, the note calls for supply chain due diligence to verify the ultimate destination and end user. Eleview’s use of a Finnish forwarder supporting the Russian postal system and a Kazakh shipper marketing CIS delivery illustrates the importance of tracing the chain to the true recipient, validating license coverage where required, and rejecting incomplete or implausible end use narratives.
   
   
4. Data trails may reveal true destinations. The note encourages the use of available information to spot deception. In Eleview, concealed Russian labels and recipient spreadsheets concealed the real end users. Exporters and shipping companies may consider building controls to detect mismatches (e.g., labels, tracking data, recipient lists, payment flows) and require alignment across systems and documents.
   
   
5. Ignorance of the facts is no defense. The US government sent a clear message that it will bring cases based on a theory of willful blindness, where companies and individuals – in the government’s view – should have done more along the compliance front to increase their awareness of potential diversion risks. The Statement of Facts filed in the case stated that OEE had informed them of the risks, but Eleview, Nayandin, and Borisenko disregarded red flags and “were deliberately ignorant as to whether the subject goods were to be transshipped to Russia.”
   
   
6. Ensure accuracy of EEI filed with the government. A transaction may involve multiple individuals and companies in a shipment chain, but ultimately, the US Principal Party in Interest (USPPI) is responsible for the truthfulness of data it provides to freight forwarders and for any EEI filed on its behalf. Submitting false or misleading information in connection with an EEI submission constitutes an independent violation of the EAR and can also be used as an overt act of a criminal conspiracy.

Key takeaways

US law enforcement authorities and agencies continue to focus on transshipment schemes, documentation misalignment, and indirect routings to high-risk jurisdictions, making enhanced due diligence and escalation of red flags key. Companies should consider validating the ultimate end user and destination – not just the last known intermediary – and documenting their diligence. Transshipment routes may trigger enhanced screening and end-use verification. USPPIs are responsible for ensuring that EEI and end-use/end-user certifications filed on their behalf are accurate and complete, and they are encouraged to periodically audit Automated Export System reports.

Companies may also consider, as part of KYC protocols for ultimate end users, leveraging data trails to detect and prevent deceptive practices. By investing in robust compliance training, transparent reporting, and ongoing risk assessment, organizations may reduce legal exposure, strengthen operational integrity, and position themselves to navigate evolving regulatory risks.

For more information, please contact the authors.