LEGAL · SANCTIONS

Sanctions compliance policy

Programmes we follow

As a US-incorporated company we comply with sanctions administered by OFAC (US), the EU (including Council Regs (EU) 833/2014 and 269/2014), the UK (OFSI under SAMLA 2018), the UN Security Council, and any other competent authority touching a given flight.

Pre-booking screening

Before any booking is confirmed and before any payment is accepted, we screen:

• The contracting charterer and the authorised signatory.
• All beneficial owners holding 25% or more of a corporate charterer; for trusts, the settlor, trustees, protector and named beneficiaries.
• Every named passenger.
• The payer, if different from the charterer.
• The operator and the registered owner of the aircraft, cross-checked against the national registry and the ICAO 24-bit address.
• Departure, destination and overflight states.

Aircraft beneficial-ownership look-through

Private-aviation assets are routinely held through SPVs in jurisdictions such as Cayman, Bermuda, Aruba (AWR), Guernsey and the Isle of Man. The EU 14th sanctions package (Reg. (EU) 2024/1469) tightened look-through requirements. We look beyond the registered owner to the beneficial owner of the aircraft and refuse bookings where the chain cannot be evidenced.

Russia-specific aviation prohibitions

Art. 3d of Reg. (EU) 833/2014 prohibits the sale, supply, transfer or export of aircraft and aircraft components, and the provision of insurance, maintenance, repair and brokering services, to any person in Russia or for use in Russia. We will not arrange flights into, out of, or for the benefit of any person ordinarily resident in Russia or any sanctioned Belarusian person, regardless of the flag of the aircraft.

Match handling

A potential match is treated as a true match until our Compliance Officer documents otherwise. While the review is pending, the booking is on hold, funds are quarantined, and we do not disclose the reason for the hold (tipping-off prohibition). Confirmed matches result in refusal, blocking of funds where required, and consideration of an OFAC voluntary self-disclosure or EU/UK competent-authority report.

Records

Screening evidence (including no-hit results), match-analysis memos and decision logs are retained for 10 years.

Read alongside our AML / KYC policy, broker disclosure, and charter terms.