Is it allowed for a maintenance organisation to provide maintenance services to Russian aircraft subject to the sanctions, including engines, components and parts thereof, to facilitate their storage while they are banned from operating in the EU airspace, e.g. to park aircraft for short term storage, engine preservation etc.?
Maintenance organisations are not prevented from, e.g. towing the sanctioned aircraft to a parking position where it can be stored out of the way and from fixing any leaks etc. to avoid environmental problems, but measures to retain or improve the value or airworthiness of sanctioned aircraft intended for use in Russia, are not as such allowed. For guidance on the interpretation of the restrictive measures affecting aircraft maintenance services, please consult FAQ #136169.
However, maintenance service can be made available for aircraft, including engines, components and parts thereof, owned by EU leasing companies, which are being returned from Russian operators, because at that point they are no longer operated by the Russian operator. The EU leasing company has taken control of the aircraft, engine, component, or part and may return it to a location outside Russia.
Please see however question FAQ #136906 for the situation where the asset freeze list contained in Annex I of Regulation 269/2014 applies.