If a training organisation subject to Regulation (EU) No 1178/2011 operates a simulator manufactured by a Russian manufacturer and simulating Russian aircraft is it affected by the sanctions?
The sanctions covered by Regulation 833/2014 do not limit import of goods from Russia, nor the support given by the Russian manufacturer to their use in the EU. If the training is provided to persons that are not subject to the sanctions (i.e. not Russian persons or intending to operate aircraft subject to the sanctions) it may continue also, provided that the FSTD operator is able to continue to maintain its qualification certificate. However, this answer is without prejudice to the possibility that one of the persons behind these companies would personally be mentioned in the list of persons who are subject to asset freezes. If that were the case, it would limit possibility to trade with these companies.