KYC for Transparency

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:

• 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.

• 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?