My organisation is a navigational database provider established in the EU. Am I allowed to provide updates of my product to my Russian customer?
No. Providing updates to navigational database falls under the EU restrictive measures according to which it is prohibited to sell, supply, transfer or export, directly or indirectly, goods and technology suited for use in aviation or the space industry (i.e. aircraft, spacecraft and parts thereof), whether or not originating in the Union, to any natural or legal person, entity or body in Russia or for use in Russia (ref. Art. 3c(1) of Regulation (EU) 833/2014). In addition, Article 2a of that Regulation explicitly bans the export of goods and technology which might contribute to Russia’s military and technological enhancement, such as software and technology for the “development”, “production” or “use” of navigation, airborne communication and other avionics equipment (cf. items X.D.V.001 and X.E.V.001 of Annex VII of the same regulation).