On March 18, 2022, the Department of the Commerce’s Bureau of Industry and Security (BIS) identified nearly 100 commercial and private aircraft that have allegedly “flown into Russia in apparent violations of the Export administration Regulations (EAR).” The list identifies planes owned by Russian airlines Aeroflot, AirBridgeCargo and Utair as well as Russian oligarch Roman Abramovich. In its notice, BIS stated that it is “notifying the public that providing any form of service to these aircraft requires authorization. Absent such authorization, any person anywhere—including within Russia—risks violating the EAR and would be subject to BIS enforcement actions.” A detailed listing of each airplane, the aircraft type, the tail number and the serial number is provided in BIS’ notice.
Also on March 18, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued under its Ukraine-related sanctions and pursuant to Executive Order 14065, General License (GL) No. 24. This GL authorizes the provision of certain civil maritime services performed by individuals who are ordinarily resident in the so-called Donetsk People’s Republic (DNR) or Luhansk People’s Republic (LNR) regions of Ukraine, so long as the services are performed outside of these regions and are not performed on behalf of any entities located or organized under the laws of these regions of Ukraine.