Due to the military conflict on the territory of Ukraine, the European Union has decided to impose the strictest sanctions against Russia.

These sanctions also affect the aviation sector. In particular, EU Regulation (EU) 2022/328 severely restricts free trade in aircraft, spacecraft, and parts thereof and prohibits under Art. 3c para. 1 to sell, supply, transfer or export, directly or indirectly these goods to any natural or legal person, entity or body in Russia or for use in Russia. Art. 3c para. 3 provides the same regulation for actions such as the overhaul, repair, inspection, replacement, modification or defect rectification of an aircraft or component.

Violations of the sanctions are subject to heavy penalties

It should be noted that persons in Russia are not to be equated with Russian citizens and therefore require verification of their actual principal place of residence or business. In addition, the broad wording of indirectness also includes the operator as well as such corporate constructions where your customer itself does not indicate any relations to Russia, but either the operator or the benificial owner of the aircraft are persons in Russia or intend to use the aircraft in Russia.

A comprehensive “Know your customer”-process (as well as a “know your operator”-process) is therefore unavoidable, as violations of the European sanctions can be punished with fines of up to EUR 500,000.00 under German law.