Can maintenance services be provided to aircraft operated by an EU operator which is owned by a Russian citizen/entity?
Answer
A maintenance organisation should first identify whether a listed individual or entity under EU sanctions* owns or controls the aircraft.
If this is the case, this individual or entity is subject to an asset freeze and a prohibition to make funds and economic resources hence the services should not be provided.
Furthermore, as to the allowability to provide maintenance services, maintenance organisations are invited to consult the guidance provided in FAQ #136169 regarding the interpretation of Article 3c of Regulation (EU) No 833/2014 as regards aircraft to be used in Russia.
Should maintenance services be possible according to Article 3c, please note that Article 3d of Regulation (EU) No 833/2014 forbids the operation in the EU of aircraft operated by Russian air carriers, any Russian registered aircraft, and of any non-Russian-registered aircraft which are owned or chartered, or otherwise controlled by any Russian natural or legal person, entity or body. Hence, such aircraft may (unless owned or controlled by an individual or entity subject to an asset freeze/prohibition to make funds and economic resources) receive maintenance services in the EU but be prohibited from flying.
*This can be checked in the Financial Sanctions Files:
https://webgate.ec.europa.eu/fsd/fsf#!/files