Sanction List – What is it?
Financial or trade restrictive measures against individuals, companies or entities can be adopted by states and is usually a decision taken at international level with the UN. This is typically the case for the recent sanctions against Russia, initiaed by the Council of the European Union and
These measures take the form of bans and restrictions on trade in targeted goods, technologies or services with certain countries, freezing of funds and economic resources, and sometimes restrictions on access to financial services.
Nevertheless, some states adopt unilateral sanctions – without any conciliation with the UN. This is the case for the USA.
Consequences of the EU sanctions against Russia for the aviation sector
In February 2022, the EU denied access to EU airports to all types of Russian carriers and imposed a ban on their overflight of EU airspace. This means that aircraft registered in Russia or elsewhere and leased or rented to a Russian citizen or entity cannot land at any EU airport and cannot fly over EU countries. The ban also extends to private aircraft, for example private business jets.
In addition, the EU has banned the export of goods and technology for the aerospace industry to Russia.
Sanctions imposed on individuals consist of a travel ban and an asset freeze. The travel bans prevent listed individuals from entering or transiting EU territory, whether by land, air or sea.
It should also be noted that compliance with its sanctions applies :
(a) within the territory of the Union, including its airspace
(b) on board any aircraft or any vessel under the jurisdiction of a Member State
(c) to any person inside or outside the territory of the Union who is a national of a Member State
(d) to any legal person, entity or body inside or outside the Union which is incorporated or constituted under the law of a Member State
(e) to any legal person, entity or body in respect of any business done in whole or in part within the Union.
Note: All EU sanctions are fully consistent with obligations under international law and respect human rights and fundamental freedoms.
Access the official EU text, listing designated companies and individuals here.
What happens if a company carriers a person under sanction?
A company not respecting the international sanctions can be considered as complicit with the sanctioned person or company and subject to trade ban.
Unfortunately, this is what happened to Emperor Aviation last November 2022. The business charter operator has only a Maltese AOC. In Russia, it operates as an aircraft management company without its own AOC.
The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) has designated the Malta company to have coordinated private travels for a close associate of Putin (listed in sanction list). As a result, 8 Emperor’s aircrafts, all registered in Malta, were blocked and forbidden to operate (more information in the CH aviation post).
Streamlane has launched a sanctions verification service for business aviation
Understanding the risk incurred by business aviation if they deal with person under international sanctions and the complexity for them to permanently check their clients against those lists, Streamlane has developed an automatic solution.
This new Streamlane’s service (sanction verification) compares the passengers registered on a flight with sanction lists (EU sanction list for test version), allowing business aviation operators to detect immediately individuals that are under travel ban.
Our sanction verification service is powered by our performant GOVlink platform, already integrated with major flight management systems.