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?
Answer
The sanctions covered by Regulation (EU) No 833/2014 do not limit the import of aircraft simulators from Russia, nor the support given by the Russian manufacturer to their use in the European Union. If the training is provided to persons that are not subject to the sanctions (i.e. persons not intending to operate aircraft subject to the sanctions), it may continue, provided that the flight simulator training device (FSTD) operator is able to continue to maintain its qualification certificate.
However, this answer is without prejudice to the possibility that these companies are owned or otherwise controlled by a person or entities subject to an asset freeze or prohibition of transactions. If that were the case, it would limit the possibility to trade with these companies.