KYC/CIP in U.S. Domestic Aircraft Transactions
- Required Steps: Verify identities (per FinCEN CIP), identify beneficial owners (≥25%), check OFAC sanctions lists, and confirm FAA citizenship eligibility.
- Recommended Steps: Apply Enhanced Due Diligence (EDD) for high-risk parties (e.g., politically exposed persons, complex LLCs), re-screen during the process, and verify funding sources for higher-risk deals.
- Key Risks:
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- Criminal Funds: Risk of charges and forfeiture if illicit money is involved.
- Sanctions Violations: Heavy penalties for dealing with OFAC-listed parties.
- PEP Risks: Corruption/reputation issues, even domestically.
- Aircraft History: Potential seizure if linked to crimes; unlawful if seller/UBO is sanctioned.
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- Mitigation: Use sanctions/PEP screening, bank record checks, FAA title search, and history review.
- Bottom Line: Domestic deals are simpler than international ones, but strict, consistent KYC/CIP and aircraft history checks are essential to avoid legal and reputational fallout.
AvBuyer – Aircraft Brokers: How Well do you Know Your Customer?