FAQ n.136297

If a Russian citizen has been issued with a Part-FCL licence but the person has not picked up the licence from the licensing authority yet, is it allowed to hand over the licence?


Yes, provided that the purpose of the license is to operate a non-Russian aircraft, i.e. if the person is, for example, destined to fly as an employee on an EU airline or as a private pilot. If the intention is to fly in Russia, at a Russian air carrier or Russian-registered aircraft or any non-Russian-registered aircraft that is owned or chartered or otherwise controlled by any Russian natural or legal person, entity or body then handing over the licence would be support to the use of banned aircraft or operators and hence prohibited.

Note 1: The concept of ‘control’ is understood in the ‘economic’ or ‘financial’ sense and not in the ‘technical’ or ‘operational’ sense (cf. para 48 of Judgement of the General Court Case T-233/22).

Note 2: The EU aviation law does not define ‘aircraft charter’. Member States authorities should apply the definition of ‘charter’ in accordance with their national legislation and relevant international agreements.

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