U.S. list of aircraft exported to Russia in apparent violation of U.S. export controls

The ongoing effort to identify and publicly list aircraft in likely violation of the EAR is part of BIS’s response to Russia’s invasion of Ukraine.

Apparent violation of U.S. export controls

The Bureau of Industry and Security (BIS) of the U.S. Department of Commerce has updated a list of aircraft that have flown into Russia in apparent violation of the Export Administration Regulations (EAR). The ongoing effort to identify and publicly list aircraft in likely violation of the EAR is part of BIS’s response to Russia’s invasion of Ukraine. 

BIS added 73 new aircraft and removed 12 aircraft that have been authorized to return to owners in partner countries. According to BIS, the updated list [PDF 223 KB] (March 30, 2022) is not exhaustive and will continue to be updated as circumstances warrant. 


  • Effective February 24, 2022, BIS imposed expansive and stringent controls on aviation-related items destined for Russia, including a new license requirement for specified aircraft or aircraft parts. 
  • Effective March 2, 2022, BIS imposed similar controls on Belarus. As a result, any aircraft manufactured in the United States, or that is manufactured in a foreign country and includes more than 25% U.S.-origin controlled content, is subject to a license requirement if such aircraft is destined for Russia. 

Read more on the BIS Russia-Belarus resources page


For more information, contact a professional with KPMG’s Trade & Customs services:

Doug Zuvich
Partner and Global Practice Leader
T: 312-665-1022
E: dzuvich@kpmg.com

John L. McLoughlin
Principal and East Coast Leader
T: 267-256-2614
E: jlmcloughlin@kpmg.com

Andy Siciliano
Partner and National Practice Leader
T: 631-425-6057
E: asiciliano@kpmg.com

Steve Brotherton
Principal and Global Export and Sanctions Leader
T: 415-963-7861
E: sbrotherton@kpmg.com

Luis (Lou) Abad
Principal, Washington National Tax
T: 212-954-3094
E: labad@kpmg.com

Irina Vaysfeld
T: 212-872-2973
E: ivaysfeld@kpmg.com

Amie Ahanchian
T: 202-533-3247
E: aahanchian@kpmg.com

Christopher Young
T: 312-665-3229
E: christopheryoung@kpmg.com

Gisele Belotto
T: 305-913-2779
E: gbelotto@kpmg.com

George Zaharatos
T: 404-222-3292
E: gzaharatos@kpmg.com

Andy Doornaert
Managing Director
T: 313-230-3080
E: adoornaert@kpmg.com

Jessica Libby
T: 612-305-5533
E: jlibby@kpmg.com

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