In February 2010, BIS and OFAC announced that they have entered into a joint settlement agreement with Balli Group PLC and Balli Aviation Ltd. (Balli) regarding allegations that Balli conspired to export commercial aircraft from the United States to Iran in violation of the EAR and the Iranian Transactions Regulations (ITR). The settlement includes penalties totaling US$15,000,000, a five-year suspended Denial Order, and a requirement that Balli hire an unaffiliated third-party consultant with expertise in US export control laws to conduct external audits of Balli’s compliance with US export control laws and sanctions regulations. According to BIS, between 2005 and 2008 Balli conspired with an Iranian airline to export or reexport US-origin aircraft to Iran without the required US Government authorization. In addition, BIS charged that from July to September 2008, Balli took actions prohibited by a BIS order temporarily denying export privileges to a party by engaging in negotiations with the denied party concerning three additional US-origin aircraft that had been exported from the United States and are subject to the EAR.