As the holder of a POA granted under EU regulation 748/2012 Annex I (regardless of my Principal Place of Business), can I issue a Permit to Fly for an aircraft registered in Russia, owned by a Russian entity, or to be operated in Russia?
Answer
In accordance with Article 3c (4)(a) of Regulation (EU) No 833/2014, as amended by Council Regulation (EU) 2022/328 of 25 February 2022, it is prohibited to provide technical assistance or other services related to the goods and technology suited for use in aviation or the space industry, whether or not originating in the Union, and to the provision, manufacture, maintenance and use of those goods and technology, directly or indirectly, to any natural or legal person, entity or body in Russia or for use in Russia.
Accordingly, holders of a POA granted under EU regulation 748/2012 Annex I (regardless of their Principal Place of Business) are forbidden to exercise their privileges on an aircraft registered in Russia, owned by a Russian natural or legal person, entity or body, or to be operated in Russia.
However, for an aircraft registered in the EU, operated within the EU airspace by an EU operator and owned by an EU entity regardless of its livery and end-customer, issuing a Permit to Fly for the purpose of completing the manufacturing cycle and/or re-allocating customer would not be forbidden by the existing EU sanctions on Russia.