For international aircraft deals, the need to conduct ‘Know Your Customer’ due diligence is well known. But some aspects of KYC may be less well understood by intermediates, buyers and sellers, AvBuyer's Chris Kjelgaard learns...
Every aviation industry professional involved in transacting an international purchase or lease of a business or private aircraft to or from North America or Europe is aware that substantial due diligence must be performed to satisfy exhaustive ‘Know Your Customer’ (KYC) requirements.
A forest of KYC regulations now exists globally. The rules have been developed over decades, with input from US, EU and other government departments and agencies to combat international crimes that include money laundering, bribery and corruption, terrorist financing, fraud, illegal arms exports and other export and import infractions.
In recent times, imposition of international sanctions by the NATO allies and cooperating nations against Russia, Iran, North Korea and other rogue nations (the US also includes Cuba and Venezuela in its list) has lent considerable further importance and complexity to the KYC due-diligence effort.
Much of the international KYC effort is collaborative, many different countries’ banking systems and regulatory authorities cooperating to make the sources, destinations and ultimate purposes of international money flows as transparent as possible.
But for aircraft buyers, sellers and intermediaries – brokers, dealers and aircraft managers, for instance – in Business Aviation’s dominant US market to assume that KYC and anti-money laundering (AML) rules and standards worldwide are the same as those of the US Government would be a mistake.
It is a mistake that can lead to gaps in KYC and AML due-diligence compliance when preparing to conduct an international aircraft transaction, according to aviation lawyer Forrest Owens, Principal of The Law Firm of L. Forrest Owens P.A. dba Aviation Legal Counsel.
If the due-diligence effort performed for an international deal doesn’t take account of any differences in the KYC/AML standards of the different jurisdictions involved, the transaction risks violating US law, which Owens emphasizes applies extraterritorially in aircraft deals involving US assets.
“A non-US party vetted under lax foreign rules might not meet US requirements,” Owens highlights.
That is just one of several major ‘Gotchas’ that can cause a planned international aircraft sale/acquisition or lease to flounder – not forgetting that KYC principles and due-diligence requirements also apply to aircraft deals conducted domestically within the US and other nations.
This article was originally published by AvBuyer on August 4, 2025.