Providing Any Form of Service to Listed Aircraft Is Also A Likely Violation of U.S. Law

WASHINGTON, D.C. – Today, the U.S. Commerce Department, through its Bureau of
Industry and Security (BIS), is updating its March 18, 2022, list of aircraft that have flown into
Russia in apparent violation of the Export Administration Regulations (EAR) by adding 73 new
aircraft and removing 12 aircraft that have been authorized to return to owners in partner
countries. This list is not exhaustive and will continue to be updated as circumstances warrant.
The ongoing effort to identify and publicly list aircraft in likely violation of the EAR is part of
BIS’s response to Russia’s brutal, unjustified invasion of Ukraine.

The updated list is available at the end of this press release and on BIS’s Russia-Belarus
Resources page here: https://bis.doc.gov/index.php/policy-guidance/country-guidance/russiabe…

The maintenance and updating of this list serves as notification to the public that providing any
form of service to any of these aircraft requires authorization. It is not exhaustive, however, and
the EAR’s restrictions apply in any situation in which a person has knowledge that a violation of
the EAR has occurred, is about to occur, or is intended to occur in connection with an aircraft or
other item that is subject to the EAR, whether or not such aircraft or other items are on this list.
Absent such authorization, any person anywhere—including within Russia—risks violating the
EAR and would be subject to BIS enforcement actions which could include substantial jail time,
fines, loss of export privileges, or other restrictions. By preventing these aircraft from receiving
any service, for example including from abroad, international flights from Russia on these
aircraft are effectively grounded.

BIS’s March 18 aircraft listing led to several companies submitting voluntary disclosures
regarding concerns over possible EAR violations and requesting permission to engage in
activities that may otherwise be prohibited. BIS granted these authorizations in order to allow
these aircraft to leave Russia, thereby preventing the Russian government from maintaining
operational control over the aircraft. Accordingly, the following aircraft have been removed from
the list below: VP-BBL (AirBridgeCargo), VP-BJS (AirBridgeCargo), VQ-BUP (Azur Air),
VQ-BZY (Azur Air), VQ-BEO (Azur Air), VP-BSA (Nordwind), VP-BDU (Nordwind), VP-

BSK (Nordwind), VP-BSO (Nordwind), VP-BDW / RA-73313 (Nordwind), VQ-BDC
(Nordwind), and VP-BSP (Nordwind).

Effective February 24, 2022, BIS imposed expansive and stringent controls on aviation-related
items destined for Russia, including a new license requirement for specified aircraft or aircraft
parts. Effective March 2, 2022, BIS imposed similar controls on Belarus. As a result, any aircraft
manufactured in the United States, or that is manufactured in a foreign country and includes
more than 25% U.S.-origin controlled content, is subject to a license requirement if such aircraft
is destined for Russia.

Based on publicly available information, BIS has identified a number of additional aircraft flying
from third countries to Russia since March 2, all of which are owned or controlled by, or under
charter or lease to, Russia or Russian nationals, and has listed those newly identified aircraft
below in bold. Any subsequent actions taken with regard to any of the listed aircraft, including,
but not limited to, refueling, maintenance, repair, or the provision of spare parts or services, are
subject to the prohibitions outlined in General Prohibition Ten of the EAR (Section
736.2(b)(10)), which provides:

(10) General Prohibition Ten - Proceeding with transactions with knowledge that a
violation has occurred or is about to occur (Knowledge Violation to Occur). You may
not sell, transfer, export, reexport, finance, order, buy, remove, conceal, store, use, loan,
dispose of, transport, forward, or otherwise service, in whole or in part, any item subject
to the EAR and exported or to be exported with knowledge that a violation of the Export
Administration Regulations, the Export Administration Act or any order, license, License
Exception, or other authorization issued thereunder has occurred, is about to occur, or is
intended to occur in connection with the item. Nor may you rely upon any license or
License Exception after notice to you of the suspension or revocation of that license or
exception. There are no License Exceptions to this General Prohibition Ten in part 740
of the EAR.

BIS has also updated the tail numbers of aircraft previously identified in the table below to
reflect their purported re-registration in Russia (also in bold).

The public may submit confidential enforcement tips via the BIS website:
https://www.bis.doc.gov/index.php/component/rsform/form/14?task=forms.e…,
or by calling the Enforcement Hotline at 1-800-424-2980.

These BIS actions were taken under the authority of the Export Control Reform Act of 2018 and
its implementing regulations, the Export Administration Regulations (EAR). For more
information, visit www.bis.doc.gov.