Samvel Karapetyan's Aircraft Under American Sanctions

Businessman Samvel Karapetyan's aircraft has been placed under American sanctions amid the backdrop of the Russia-Ukraine war since autumn 2022. The Russian-Armenian businessman is not directly linked to these sanctions; however, his owned aircraft has been targeted by the U.S. Department of the Treasury.

Karapetyan's aircraft has been included in the Office of Foreign Assets Control (OFAC) blacklist of the U.S. Treasury. More specifically, the blacklist features the Maltese private aviation company that operates business class jets. This company is "Emperor Aviation," founded in 2013 by Georgian Irakli Litaniashvili. It has offices in Birkirkara, Malta, and Moscow.

It is pertinent to note that all American assets of individuals and legal entities included in OFAC's blacklist, if any exist, are frozen. Moreover, U.S. citizens and companies are prohibited from engaging in any transactions with them.

Both "Emperor Aviation" and its fleet of 8 luxury aircraft, all registered in Malta, have fallen under America’s anti-Russian sanctions. These include 4 Bombardier Global Express jets, 2 Gulfstream G650 jets, and one each of Cessna Citation XLS+ and Bombardier Challenger 650. Notably, one of the Gulfstreams is owned by Sam Karapetyan, registered in the Maltese aircraft registry as 9H-SSK. The "9H" is Malta's aviation national marker, meaning that all planes registered in Malta bear this identifier, while "SSK" is the specific registration number of this aircraft. In reality, this is a combination of the initials of the Armenian businessman’s first, middle, and last names: Samvel Sargsi Karapetyan. The practice of using name initials in aircraft registration numbers is common among the wealthy.

"Emperor Aviation" employs various enticing combinations such as VIP, CEO, LUX, and BOY for its aircraft registration numbers. Such transport companies operating for wealthy owners not only cater to their needs but also conduct flights for various clients with the owners’ consent, generating revenue for both the airline and the aircraft owner.

As mentioned, Karapetyan's aircraft has been affected due to the operations of "Emperor Aviation." The company has come under scrutiny by American authorities due to its ties with Suleiman Kerimov, a billionaire close to Russian President Vladimir Putin. In September 2022, OFAC had already blacklisted Kerimov based on his close connections to the Russian authorities. Moreover, in 2018, the Russian billionaire had also been placed on the blacklist.

By November 2022, the sanctions extended to adult family members of Kerimov, including his wife, Firuzai, daughters Gulnara and Amina, and son Said. The EU, UK, and Switzerland have also imposed sanctions on Said. Additionally, four French companies owned by Gulnara Kerimova and their Swiss manager are also included in the OFAC blacklist. This list does not stop there; other individuals and companies linked to the Kerimovs have also ended up on the U.S. list, including "Emperor Aviation" with its 8 aircraft.

On November 14, 2022, the U.S. Treasury announced that this company with offices in Malta and Russia has conducted luxurious travel for Suleiman Kerimov's family members, including Gulnara, even after Russia invaded Ukraine on February 24, 2022.

The American side has not disclosed which specific aircraft provided services to the Kerimovs, but it stated that "Emperor Aviation" was placed on the blacklist because it operated in the aviation segment of the Russian economy and material support, sheltered, or provided financial, material, or technological assistance or services to Gulnara Kerimova.

As previously mentioned, U.S. authorities prohibit any transactions by American citizens or organizations with entities and individuals included in OFAC's blacklist. However, the same OFAC issued a general license (General License (GL) 40C) on November 14, 2022, which allows a restrictive exception for several companies on the blacklist, including "Emperor Aviation." According to this, "Emperor Aviation" is allowed to acquire certain goods, technologies, or services necessary to ensure safety in civil aviation from the U.S. However, the condition is that the aircraft must be registered exclusively outside Russian borders, and the goods and technologies must be exported, re-exported, and services provided only for the needs of civil aviation.

The professional site Ch-aviation.com noted that this would allow "Emperor Aviation" to keep its 8 aircraft in flight-worthy condition as long as the operator’s transactions do not involve Russian financial services or individuals under sanctions. The same site reported that OFAC's licensing exceptions also apply to Russian aircraft manufacturing companies and lessors but not to air transporters.

It is worth noting that the Bombardier planes in the Maltese operator's fleet are Canadian-made, while the Gulfstreams and Cessnas are American. This means that without exceptions, the aircraft of "Emperor Aviation," which has come under sanctions, would become temporarily unfit for flights due to lack of proper technical maintenance. Nonetheless, according to flight tracking websites, none of "Emperor Aviation's" 8 aircraft have taken to the skies after November 2022.

Karapetyan's "Gulfstream G650" (9H-SSK) last flew from Yerevan to Hanover, Germany, on August 29, 2022. Furthermore, the aircraft remains registered in Malta.

Regarding "Emperor Aviation" and Samvel Karapetyan’s aircraft, "Hetq" had written in 2018 about how 9H-SSK had transferred a delegation led by then Prime Minister Karen Karapetyan from Yerevan to Zurich to attend the Davos Economic Forum in January 2018, and prior to that, in July 2017, it had transported Armenian President Serzh Sargsyan to Tehran for the swearing-in ceremony of the Iranian President.

Details available on the source site.