VZCZCXYZ0001
PP RUEHWEB

DE RUEHMO #3556 3441225
ZNR UUUUU ZZH
P 091225Z DEC 08
FM AMEMBASSY MOSCOW
TO RUCPDOC/USDOC WASHDC PRIORITY
INFO RUEHC/SECSTATE WASHDC 1056
RHMFIUU/US CUSTOMS AND BORDER PROTECTION WASHINGTON DC

UNCLAS MOSCOW 003556 
 
SIPDIS 
 
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 didn't 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 (techt@yandex.ru).  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. 
(FCS MOSCOW/JMARKS/PLISTON) 
BEYRLE