What the Latest EU Sanctions Derogation Means for Aircraft Lessors

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Through Council Regulation (EU) 2022/328 of February 25, 2022, the European Union introduced new sanctions relating to, among other things, Russian aggression in Ukraine. The regulation amended Regulation (EU) No 833/2014 to introduce a raft of new prohibitions, with the new Article 3c most relevant to aircraft leasing and financing. Pursuant to Article 3c, among other things, it has been prohibited since February 26, 2022 (or March 28, 2022 to the extent that contracts were concluded prior to February 26, 2022) to: