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FAQ n.136187

If the aircraft is rented by an EU or 3rd country resident, but the flight is from Russia to the EU, is it allowed? Alternatively, if there is at least one Russian citizen who is not on the sanction list, is it allowed to approve these flights?

Answer

Landing or taking off from the EU is allowed only if (i) the aircraft is not operated by a Russian air carrier, (ii) the aircraft is not registered in Russia (iii) the aircraft is not owned or chartered, or otherwise controlled by any Russian natural or legal person, entity or body; and (iv) there are no persons on board the aircraft who are subject to a listing under the Sanctions Regulations.

In line with article 3d(1) it shall be prohibited for any aircraft operated by Russian air carriers, including as a marketing carrier in code-sharing or blocked-space arrangements, or for any Russian registered aircraft, or for any non-Russian-registered aircraft which is owned or chartered, or otherwise controlled by any Russian natural or legal person, entity or body, to land in, take off from or overfly the territory of the Union.

Therefore, it should be noted that the Regulation does not forbid to take Russian citizens on board, however aircraft cannot be rented (chartered) by Russian citizens. If there are more people on board (10 people rented aircraft, while 2 of them are RU citizens) it is up to the authority to make sure there is no circumvention of the prohibition.

Last updated
11/08/2022

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