The US government is expanding economic sanctions related to the training of Chinese military pilots by private firms.

Washington’s Bureau of Industry and Security (BIS) on 2 July announced it has added six aerospace companies to the so-called “Entity List”, which identifies individuals, companies and organisations which “have been involved, are involved or pose a significant risk of being or becoming involved in activities contrary to the national security or foreign policy interests of the United States”, according to the agency.

The designation subjects targeted entities to export restrictions and licensing requirements under the USA’s Export Administration Regulations law, which aims to prevent the spread of technologies and goods deemed relevant to national security by the BIS.

Among the six firms identified in the latest sanctions expansion are two companies apparently owned or operated by former military test pilots; one with the UK Royal Air Force (RAF) and another with the South African Air Force (SAAF).

Grace Air, based in South Africa’s Western Cape province, and England-headquartered Livingston Aerospace were both targeted by the BIS over links to the Test Flying Academy of South Africa (TFASA) – a flight school sanctioned in 2023 over the alleged training of Chinese military pilots.

Chengdu J-20s parade 1 October 2019 - WC

Source: Wikimedia Commons

Beijing has been seeking to rapidly expand China’s military capability, including with advanced aerospace platforms like the Chengdu J-20 low-observable fighter

The BIS claims TFASA was using “Western and North Atlantic Treaty Organization sources” to train China’s military forces. However, the latest filing does not specify exactly what connections were identified between TFASA and the two firms.

Gloucestershire-based Livingston Aerospace is headed by Craig Penrice, according to filings with the UK government.

Penrice’s occupation is listed as “test pilot” in the Companies House registry, which identifies him as the director of Livingston Aerospace with at least 75% ownership of the firm. His LinkedIn page lists 16 years as a fighter pilot with the RAF, followed by nearly 17 years with BAE Systems a test pilot and aircrew advisor.

Although Livingston Aerospace is listed as an active company, it does not appear to have a website containing any public offering of services. The firm submitted an annual financial filing in March that did not include a detailed profit and loss statement, but lists a modest £53,166 ($67,719) in net assets.

Penrice lists experience with a number of fighter aircraft, including the BAE Hawk trainer, Panavia Tornado, Boeing F-15 and Eurofighter Typhoon.

Chengdu J-20 pilot inspection

Source: Chinese social media @pupu-2012

A People’s Liberation Army Air Force J-20 pilot inspects his aircraft prior to a 1 October 2019 flight. Western officials allege China is recruiting former NATO officers to train Chinese aviators

South Africa’s business registry lists Jean Jacques Rossouw as the director of Grace Air, based in Oudtshoorn, Western Cape province. A LinkedIn page for Rossouw lists 10 years as a pilot and flight-test engineer in the SAAF and identifies him as the chief executive of TFASA.

Although the TFASA website does not list any individual officers or instructors, an image featured on the “TFASA People” page matches Rossouw’s LinkedIn profile photo.

On the business networking site Rossouw also identifies himself as director of the International Flight Training Academy (AIFA) in South Africa, described as a joint venture between TFASA and the Aviation Industry Corporation of China.

Both Grace Air and AIFA list Oudtshoorn airport as their home base.

Rossouw on LinkedIn describes the organisation as “one of only 28 schools worldwide with [Civil Aviation Administration of China] accreditation to train Chinese cadets for the Chinese airline industry”.

Instructional offerings listed on the AIFA website include private and commercial pilots licenses, with options for instrument, night and instructor ratings. Former SAAF pilot Mike Bates is listed as the current AIFA chief executive on the company website. His biography shows both fixed- and rotary-wing aviation experience with the SAAF.

The school says its fleet includes a Piper 161 Warrior, Cessna 172 Skyhawk, Piper Seminole and King Air C-90.

In a 5 June statement posted to its website, TFSA acknowledged it is “one of many providers of aviation training services to China”, but also argued that similar service providers in the USA, Canada and Europe have not faced “unfair harassment from US government agencies” for working with Chinese students.

“TFASA does not provide any classified military training, nor train frontline pilots, and all training is based on open-source material or material provided by clients,” the company says. 

Notably, TFASA says it does not employ US nationals and has ended the employment of all UK nationals. FlightGlobal reached out to TFASA for clarification regarding the school’s relationship to UK-based Livingston Aerospace, but had not received a response at the time of publication.

The South African company also says it has “never deliberately sought to head hunt serving military personnel from NATO countries”.

However, Western intelligence officials allege former NATO service members are often the target of recruiting efforts by China-connected flight training providers, such as TFASA.

A joint bulletin released on 5 June by the USA, UK, Canada, Australia and New Zealand claimed China offers “lucrative contracts” to NATO officers with “vague details on the ultimate customer”, typically through seemingly neutral third parties.

“China’s People’s Liberation Army (PLA) has been aggressively recruiting Western military talent to train their aviators, using private firms around the globe that conceal their PLA ties and offer recruits exorbitant salaries,” said Michael Casey, director of the US National Counter Intelligence and Security Center.

In addition to Livingston Aerospace and Grace Air, the latest BIS sanctions also identify two Chinese firms and two from the United Arab Emirates.

Dubai-based Mega Fast Cargo and Mega Technique General Trading are alleged to have “repeatedly engaged in dilatory or evasive conduct, including the provision of false, misleading or incomplete information, during end-use checks”, the BIS says.

Mega Fast Cargo was also found to have shipped US-origin commodities to Russia, in violation of trade restrictions related to Moscow’s war in Ukraine.

Two Chinese firms were also sanctioned over “roles in training military personnel and supporting unauthorised military advancements”, according to Alan Estevez, US under secretary of commerce for the BIS.

Global Training Solutions and Smartech Future, both based in Hong Kong, were also identified by the agency for unspecified connections to TFASA.