Katten: BIS grants authorization of aircraft to leave Russia and updates list of aircraft operating in or to Russia in violation of export controls

In a March 30 press release, the US Commerce Department updated its March 18 list of aircraft that have flown into Russia in apparent violation of Export Administration Regulations by adding 73 aircraft and removing 12 aircraft that have been authorized by the BIS to return to their owners in “partner countries.” The press release reiterates the risk discussed in our previous Aviation Advisory of violation of US law even to lessors and financers whose aircraft continue to be flown only within Russia.  The BIS has acknowledged that several companies have already filed voluntary disclosures on potential violations, to allow the