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EU restrictive measures against Russia

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Common Issues - Restrictive measures Russia

What is the legal basis for the EU restrictive measures against Russia?

What does “technical assistance” mean?

Do the Sanction Regulations restrict a Russian citizen holding a personnel licence issued in accordance with Regulation (EU) 2018/1139 to exercise the privileges of the licence inside the EU (e.g. flying an aircraft for private purposes or for an EU airline, conducting maintenance for an EU aircraft, working in an EU Part 145 organisation, working as cabin crew in EU airlines)?

Do the sanctions apply to persons with dual nationality, i.e a person who holds both a Russian passport as well as an EU/non-EU passport?

Is it allowed to execute contracts that have been concluded before the adoption of the sanctions (e.g. deliveries with EASA Form 1, Form 52)?

We understand that following evaluation of the terms „technical assistance” and “other services” as mentioned in the Sanctions Regulations, EASA has suspended certificates issued to organisations in Russia. Is this interpretation also applicable to approvals and certificates issued by EU Member States in the same way?

Design certificates and design organisation approvals - Restrictive measures Russia

What actions has EASA taken concerning design certificates and design organisation approvals?

Do the EU sanctions regulations towards Russia supersede the continued airworthiness obligations of the EU type certificate holders (TCHs) stemming from Regulation (EU) No 748/2012, hence the continued airworthiness (CAW) support to Russian operators and owners should be stopped?

Does the definition of “technical assistance” cover the provision of safety-related information?

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)?

Are EU organisations permitted to answer questions received from FATA about on-going validation of modifications?

Will EASA issue flight condition to Russian products issued with an EASA type certificate?

Can a holder of a design organisation approval (DOA) apply to EASA for a supplemental type certificate (STC) or other design approval (e.g. minor change) for a product, part or non-installed equipment, that is to be installed on an aircraft operated by a Russian operator?

Can a holder of a design organisation approval (DOA) issue design approvals under its privileges, that is to be used on an aircraft operated by a Russian operator?

EASA suspended aircraft type certificates issued to organisations in Russia. Can the individual aircraft of these types registered in EU Member States continue to be operated by EU operators?

Will EASA continue to monitor, and eventually adopt FATA Airworthiness Directives for Russian types whose type certificate was suspended by EASA?

Will ADs issued by EASA to Russian types that were recently suspended remain valid?

My organisation is holder of a type certificate issued by EASA and a Russian operator of my product reported an occurrence to us. Are we allowed to have an exchange with the Russian operator to investigate the reported occurrence?

Production organisations - Restrictive measures Russia

As the holder of a Production Organisation Approval (POA) granted under EU regulation 748/2012 Annex I (regardless of my Principal Place of Business), can I release engines, propellers, parts or appliances with an EASA Form 1 to a customer in Russia, or for use in Russia?

As the holder of a POA granted under EU regulation 748/2012 Annex I (regardless of my Principal Place of Business), can I have approved or unapproved location(s) in Russia from where I exercise my privileges granted under 21.A.163?

As the holder of a POA granted under EU regulation 748/2012 Annex I (regardless of my Principal Place of Business), can I issue the EASA Form 52 (Aircraft Statement of Conformity) or the EASA Form 53 (Certificate of Release to Service) for an aircraft registered in Russia, owned by a Russian entity, or to be operated in Russia?

As the holder of a POA granted under EU regulation 748/2012 Annex I (regardless of my Principal Place of Business), can I issue a Permit to Fly for an aircraft registered in Russia, owned by a Russian entity, or to be operated in Russia?

Aircraft maintenance and continuing airworthiness - Restrictive measures Russia

What actions has EASA taken in the domain of aircraft maintenance?

As an organisation approved in accordance with Regulation (EU) 1321/2014, am I allowed to provide any services to Russian operated or registered aircraft?

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.?

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?

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?

Training and licensing of maintenance personnel - Restrictive measures Russia

What actions has EASA taken concerning training of maintenance personnel?

I am an EU national and holder of a Part-66 licence. Am I allowed to work, either within or outside the EU, on Russian owned or operated aircraft?

The Sukhoi Superjet type certificate is suspended by EASA. In the Member States there are Part-66 licences containing this type rating. Does the competent authority need to suspend this rating in those maintenance licences?

As an organisation approved by a Member State in accordance with Annex IV (Part-147) of Regulation (EU) 1321/2014 and my principal place of business is within the territory of the EU, am I allowed to provide training to Russian citizens?

As competent authority of an EU Member State, am I allowed to issue Part-66 licence to a Russian national?

Aircrew training and licensing - Restrictive measures Russia

What actions has EASA taken in the domain of pilot licensing?

I am an EU national and holder of a pilot licence issued in accordance with Annex I (Part-FCL) to Regulation (EU) No 1178/2011. Am I allowed to fly, either within or outside the EU, a Russian owned, registered or operated aircraft?

As an ATO/DTO/organisation operating FSTDs subject to Regulation (EU) No 1178/2011 and having principal place of business within the EU territory, am I allowed to provide either theoretical or practical training, in an FSTD or in an aircraft, to Russian citizens?

I am a holder of an examiner certificate issued in accordance with Annex I (Part-FCL) of Regulation (EU) No 1178/2011. Am I allowed to conduct skill tests, proficiency checks or assessments of competences to Russian license holders or to Russian nationals, who hold either a Part-FCL or other third country license (i.e. for the purpose of obtaining an EU Part-FCL licence, rating or certificate)?

Is it allowed for Russian citizens to take theoretical knowledge examination? If it is not allowed, how to proceed with persons who have already started the examination but have not yet finished?

Is it allowed to issue a Part-FCL licence on the basis of a Russian licence? Is there a difference if a person is Russian citizen or not? If not, what to do with persons who have already started the process?

Is it allowed to issue a validation of a pilot licence to a Russian citizen, for example if the pilot flies for an EU based company?

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?

If Ukrainian pilot wants to validate his/her licence, but getting a verification from Ukrainian CAA is limited or even impossible, what are the options for such pilot to get a Part-FCL license?

If a Russian citizen has been issued with a Part-FCL licence but the person has not picked the licence up from the licensing authority yet, is it allowed to hand over the licence?

Can Russian citizens apply for an EU medical certificate issued in accordance with Regulation (EU) No 1178/2011?

Aircraft operations - Restrictive measures Russia

Are aircraft registered in Russia or operated by Russian operators allowed to fly into the EU?

The Sanctions Regulation prohibits any non-Russian-registered aircraft which is owned or chartered, or otherwise controlled by any Russian natural to land in, take off from or overfly the territory of the Union, except in case of an emergency landing or emergency overflight. Does this prohibition coverall also natural persons with a dual nationality?

If the aircraft is rented by an EU or 3rd country resident, but the flight is from Russia to the EU, is it allowed? Alternatively, if there is at least one Russian citizen who is not on the sanction list, is it allowed to approve these flights?

What happens to the dry and wet leasing arrangements and code-sharing agreements between the EU AOC holders and Russian aircraft operators?

My organisation is a navigational database provider established in the EU. Am I allowed to provide updates of my product to my Russian customer?

EASA TCO authorisations - Restrictive measures Russia

Are Third Country Operator authorisations issued by EASA to airlines from Russia still valid?

Is a TCO one off-notification under TCO.305 of Regulation (EU) No 452/2014 needed from a Russian operator for flight(s) performed under an exemption granted by a Member State in accordance with Article 3d (3) of Regulation (EU) No 833/2014?

Operation of unmanned aircraft - Restrictive measures Russia

Are Russian unmanned aircraft operators registered in the EU Member State allowed to operate unmanned aircraft within the EU?

How to conduct in a case, where a drone operator from Russia wants to conduct a drone show in MS. The application is issued by MS applicant, but every document they have provided us (including operations manual and risk assessment), indicates clearly that the actual operator is indeed Russian operator.

ATM/ANS - Restrictive measures Russia

Are Aeronautical Database Suppliers (DAT) located in the EU permitted to continue to supply aeronautical information to customers in Russia?