EU Sanctions Update: Guidance Published On The 'No Russia Clause'

The EU has continued to tighten economic sanctions against Russia in recent months with the introduction of the 12th sanctions package on 18 December 2023 and the 13th sanctions package on 24 February 2024.

Of particular relevance from an aviation perspective, the 12th sanctions package has introduced an obligation on EU based aircraft lessors, airlines and manufacturers when selling, supplying, transferring or exporting aircraft, engines and parts to a third (i.e. non-EU) country, with the exception of certain partner countries (listed below), to contractually prohibit the re-exportation to Russia and re-exportation for use in Russia of such goods (the "No Russia Clause")¹.

The purpose of the No Russia Clause is to combat the circumvention of EU export bans and, more specifically, the situation where goods exported to third countries are re-exported to Russia. In practical terms, "re-exportation" would include the sale, leasing and sub-leasing of aircraft,