EU sanctions and the no re-export to Russia requirements

Who has to comply with the Regulation? The Regulation only applies to EU person exporters who are selling, supplying, transferring, or exporting the targeted goods (including aircraft) to third-country counterparts outside of the EU but who themselves are not in a partner country.

Affected exporters will include airlines and operating lessors located in any EU Member State, and also any special purpose companies established or resident in an EU Member State for leasing aircraft in structured transactions (Ireland is a favoured location for such special purpose companies).

Please see full publication below for more information.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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