While the USDoT consent order contains plenty of legalese, the bottom line appears to be that VA applied for and received from the USDoT a “statement of authorization” that obligates VA to comply with certain FAA requirements. I suspect that SoA also specifies consequences for FAA violations that VA agreed to. Thus, the authority for USDoT to fine VA, a foreign carrier.
VA is not contesting either the fine or the authority of USDoT to impose the fine.