Am I allowed to send any type of technical information, including safety information related to the design, to my customer in Russia, or maintain my Russian customer’s access to my dedicated IT system for such information (e.g. service bulletins, manuals)?
Answer
No, the provision of technical information, including safety information related to the design, is considered technical assistance to manufacture, maintenance and/or use of an aircraft under the sanctions. Please refer to the definition of “technical assistance” laid down in Article 1(c) of Regulation (EU) No 833/2014, as amended by Regulation (EU) 2022/328. Only information accessible to the public (e.g. EASA Safety Publications Tool — Airworthiness Directives) remains accessible to Russian customers.
In addition, pursuant to Article 3c(4)(c) of Regulation (EU) No 833/2014, as amended by Regulation (EU) 2023/1214 of 23 June 2023, it is prohibited to sell, license or transfer in any other way intellectual property rights or trade secrets as well as grant rights to access or reuse any material or information protected by means of intellectual property rights or constituting trade secrets related to the goods and technology suited for use in aviation or the space industry and to the provision, manufacture, maintenance and use of those goods and technology, directly or indirectly to any natural or legal person, entity or body in Russia or for use in Russia.