Is it allowed for a maintenance organisation approved by EASA or an EASA Member State under Part-145 to provide Russian operated or registered aircraft maintenance services e.g., to park aircraft for short term storage, engine preservation etc.?
No, according to Article 3(c) of Regulation (EU) No 833/2014, as amended by Regulation (EU) 2022/328, such aircraft cannot benefit from maintenance services regulated under Regulation (EU) 1321/2014. However, maintenance organisations are not prevented from, e.g. towing the aircraft to a parking position where it can be stored out of the way and from fixing any leaks etc. to avoid environmental problems, but measures to retain or improve the value or airworthiness of the aircraft are not as such allowed.
However, this service can be made available for aircraft owned by EU leasing companies, which are being returned from Russian operators, because at that point they are no longer operated by the Russian operator. The EU leasing company has taken control of the aircraft and may return it to a location outside Russia.
Is it allowed for an EU maintenance organisation to perform maintenance in Russia in accordance with Regulation (EU) 1321/2014 on EU registered aircraft in order for them to meet the airworthiness requirements necessary for the return flight or in order to meet their leasing return conditions?
Yes, assuming the aircraft is not in Russian register and has been returned to the lessor’s control. This is allowed because once the aircraft has been returned to the (non-Russian) lessor it is no longer chartered, leased or otherwise controlled by a Russian person.
Is it allowed for a maintenance organisation approved by EASA under Part-145 to perform maintenance on components and provide such components to a non-EU, non-Russian operator, if this operator operates the aircraft to Russia?
Yes, if this aircraft is not being used to fly domestically in Russia, or otherwise to circumvent the sanctions (N.B. Article 12 prohibits any measures by a third party that might result in circumventing the sanctions).