The European Union's 20th Russia sanctions package, adopted in April, combined a sweeping set of restrictions targeting Russia's energy revenues, trade, financial services, crypto activity and military-industrial capacity with a first-of-its-kind use of the EU's anti-circumvention tool against Kyrgyzstan. As Reuters reported, the restrictions covered goods including metal-cutting machinery and communications equipment such as modems and routers seen as high-risk for re-export to Russia. Bishkek called for a transparent, depoliticized dialogue with the European Commission and rejected suggestions that its companies and banks are assisting circumvention. The package added 120 new individual listings — the largest single-package addition in two years.
Despite restrictions imposed since February 2022, Russia's supply chains have not vanished but have shifted through third countries, brokers, free zones, banks and maintenance providers. Russian airlines continue to operate Airbus and Boeing aircraft despite limits on certified parts, maintenance, technical support and aircraft leasing. Commercial papers, contracts and freight records reviewed by EU Today show how Russian aviation entities continued to appear in international supply-chain documentation involving suppliers and maintenance-linked companies in the UAE, Jordan and Kyrgyzstan after February 2022. The records by themselves do not establish deliberate circumvention, hidden ownership or criminal wrongdoing; they document that Russian operators stayed visible inside the global aviation supply chain after Western restrictions tightened.
A first cluster of documents centers on Golden Falcon Aviation FZE, based in Ras Al Khaimah. A 24 March 2022 contract names Golden Falcon as seller and S7 Engineering LLC at Domodedovo Airport as buyer for civil aircraft tools, test and ground equipment. A 16 March 2022 purchase order lists Siberia Airlines JSC as buyer, gives Golden Falcon's address as RAK Free Trade Zone Technology Park and identifies Domodedovo as the shipment destination. A 23 March 2022 pro forma invoice is addressed to S7 Technics and includes banking details at Emirates NBD and the National Bank of Ras Al Khaimah. The wider material also references Casper Aviation Spares Trading FZE and U.C.A Aviation Spares Trading FZE, both in the Umm Al Quwain Free Trade Zone; a 3 March 2023 purchase order from U.C.A names Siberia Airlines as buyer for an inspected Director-CIDS unit valued at $158,000, with Domodedovo as the destination.
A second and more pointed strand involves Jordan-registered Aerospace Technical Services (ATS). A 12 January 2023 purchase order from Siberia Airlines lists ATS as supplier of a repaired auxiliary power unit valued at $610,000, with priority marked "Aircraft on Ground" and shipment destination Tolmachevo Airport in Novosibirsk. A 6 March 2023 contract addendum names Mahdi Al Tahaineh as ATS Chief Executive Officer; the file also contains EASA-linked approval material for ATS Technic in Dubai under reference EASA.145.1008. In December 2023, the U.S. Treasury's OFAC designated "A T S Heavy Equipment and Machinery Spare Parts Trading L.L.C." under the Russia sanctions program for delivering millions of dollars of aircraft parts to Russia. EU Today does not assert that ATS Group or ATS Technic is the same legal entity as the OFAC-listed company, but notes documentation linking Mahdi Suliman Hamed Al Tahaineh as an investor associated with A T S Heavy Equipment. For the supply chain, the file's central signal is clear: the EU's first anti-circumvention move against Kyrgyzstan is likely a precursor to deeper listings targeting Russia-bound aviation spare-parts corridors running through UAE free zones and Jordan.
Key Takeaways:
1. The EU's 20th Russia sanctions package used the anti-circumvention tool against Kyrgyzstan for the first time, restricting exports of metal-cutting machinery and modem-router communications gear.
2. EU Today published commercial documents tracing post-February-2022 aircraft-parts flow from UAE-based Golden Falcon, Casper and U.C.A and Jordan's ATS into S7 Engineering and Siberia Airlines.
3. A 12 January 2023 purchase order shows Siberia Airlines ordering an ATS auxiliary power unit valued at $610,000 with Aircraft on Ground priority, shipped to Tolmachevo Airport in Novosibirsk.
4. OFAC designated 'A T S Heavy Equipment and Machinery Spare Parts Trading L.L.C.' in December 2023 for supplying millions of dollars of aircraft parts to Russia; EU Today does not allege ATS Group is the same entity.
5. The package added 120 new individual listings — the largest single-package set in two years — and signals further moves targeting Russia-bound aviation spare-parts corridors.
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