Sanctions targeting former post-Soviet countries suspected of facilitating the transfer of restricted goods to Russia have once again placed Central Asia at the forefront of discussions over enforcement in Europe. Kyrgyzstan has advocated for a transparent, depoliticised dialogue with the European Commission following the European Union’s recent expansion of its sanctions package against Russia, which now includes Kyrgyz companies and financial institutions. The government in Bishkek has firmly rejected allegations of assisting in sanctions circumvention, emphasising that its companies and banks operate in strict compliance with both domestic laws and international obligations.
These measures are part of the EU’s 20th sanctions package against Russia, adopted in April. The Council of the EU has characterised this package as a comprehensive array of restrictive measures aimed at diminishing Russia’s energy revenues, trade capabilities, financial services, cryptocurrency activities, and military-industrial potential. Significantly, the package also includes 120 new listings, the most extensive set introduced in the past two years.
This package is noteworthy for another reason: it marks the first time the EU has employed its anti-circumvention tool against Kyrgyzstan, which restricts the export of specific goods due to concerns regarding their potential re-export to Russia. According to Reuters, the restrictions cover items such as metal-cutting machinery and communications equipment, including modems and routers.
The situation in Kyrgyzstan exemplifies a broader challenge within European sanctions policy. Since Russia’s full-scale invasion of Ukraine in February 2022, the EU, the United States, and allied governments have enacted measures designed to limit Russian access to finance, technology, industrial equipment, aviation services, and dual-use goods. Nevertheless, Russia’s supply chains have not dissipated; rather, they have been redirected through third countries, brokers, logistics firms, free zones, banks, and maintenance providers.
Civil aviation provides a notable illustration of ongoing developments in the industry. Despite facing significant restrictions on access to certified parts, maintenance, technical support, and aircraft leasing, Russian airlines continue to operate Western-built aircraft, including models from Airbus and Boeing. Maintaining the operational status of these aircraft requires a reliable supply of components, repairs, and documentation.
Recent analysis of commercial documents, contracts, and freight records by European Interest reveals that Russian aviation entities have been involved in commercial activities with suppliers and maintenance companies located in the United Arab Emirates, Jordan, and Kyrgyzstan since February 2022. It is important to clarify that European Interest does not assert that every transaction referenced in these records was unlawful, unlicensed, non-compliant, or in violation of sanctions.
Furthermore, the documents themselves do not serve to establish any deliberate circumvention, hidden ownership, or criminal conduct by any individuals or companies identified. Nonetheless, these records are relevant because they illustrate that Russian aviation operators remained listed in international supply-chain documentation even after the imposition of Western restrictions in response to the ongoing conflict.
Documents related to Golden Falcon Aviation FZE in Ras Al Khaimah include a contract dated 24 March, 2022, identifying Golden Falcon as the seller and S7 Engineering LLC as the buyer for aircraft equipment, such as tools and ground support gear, with S7 Engineering located at Domodedovo Airport in Moscow.
Additional records show that Golden Falcon is a supplier to Siberia Airlines JSC. A purchase order dated 16 March 2022 lists parts, including an insert and rivets, for shipment to Domodedovo Airport. Another document from 21 March 2022 confirms Golden Falcon’s role as a supplier to S7 Engineering for an inspected FCU board. A pro forma invoice dated 23 March 2022 is addressed to S7 Technics at the same airport and includes banking details for Golden Falcon Aviation FZE.
The material also references Casper Aviation Spares Trading FZE, based in the Umm Al Quwain Free Trade Zone, which supplies aircraft spare parts and related equipment. A purchase order dated 3 March 2023 names UCA Aviation Spares Trading FZE as a supplier to Siberia Airlines JSC for an inspected Director-CIDS unit valued at $158,000, to be shipped to Domodedovo Airport. The source material provided to European Interest claims connections between Golden Falcon Aviation, Casper Aviation, UCA, and certain individuals, but those claims are not presented here as established fact. The key point is that Russian aviation-linked entities appear in post-invasion commercial documents involving UAE-based suppliers and logistics routes.
A second strand concerns Aerospace Technical Services, identified in the documents as a Jordan-registered aviation services company. Public company materials on the ATS website describe Mahdi Al-Tahaineh as the founder of ATS, while a contract addendum reviewed by European Interest names him as the Chief Executive Officer of Aerospace Technical Services.
ATS is an aerospace services provider offering aircraft spare parts, engine solutions, auxiliary power units, landing gear, line maintenance, and leasing services, as well as cargo solutions and MRO (maintenance, repair, and overhaul). The company has offices in Jordan, Dubai, Greece, and the US (its US office located at 1 Chisolm Trail Road, Suite 450, Round Rock, Texas).
On 12 January 2023, Siberia Airlines JSC placed an order with Aerospace Technical Services in Jordan for a repaired auxiliary power unit valued at $610,000, marked as “Aircraft on Ground,” for shipment to Tolmachevo Airport in Novosibirsk.
A 6 March 2023 addendum identifies Aerospace Technical Services as a Jordan-registered company, led by CEO Mahdi Al Tahaineh. This addendum pertains to Contract No. S7E-SN-0156 from 6 June, 2022, with S7 Engineering LLC at Domodedovo Airport and includes necessary signatures and banking details. The ATS file also contains EASA approval documentation for ATS Technic in Dubai, referencing EASA approval 145.1008 for certain Airbus and Boeing aircraft.
Mahdi Suliman Hamed Al Tahaineh has been referenced in several documents reviewed by European Interest. One particular document identifies him as an investor connected to A T S Heavy Equipment & Machinery Spare Parts Trading LLC. Notably, in December 2023, the US Treasury designated ATS Heavy Equipment & Machinery Spare Parts Trading for supplying millions of dollars’ worth of aircraft parts to Russia. This company is listed under the Office of Foreign Assets Control (OFAC) sanctions programme concerning Russia.
It is essential to clarify that European Interest does not assert that Aerospace Technical Services, ATS Group, or ATS Technic are legally identical to A T S Heavy Equipment & Machinery Spare Parts Trading LLC. Additionally, it doesn’t state that the OFAC has designated Mahdi Al Tahaineh or these companies. This clarification is intended to emphasise that aviation businesses with similar names or affiliations, as well as their management roles, ownership records, and trading histories, may play a significant role in the context of sanctions due diligence. Any conclusions regarding corporate linkages, control, or responsibilities would necessitate formal registry records and regulatory assessments.
The third set of materials relates to Aeroparts AOG and the Royal Aircraft Maintenance Company (RAMC). A contract dated 25 June, 2022, identifies Aeroparts AOG as the seller and S7 Engineering LLC as the buyer for aircraft spare parts, components, and equipment. It lists Aeroparts AOG at Dubai International Airport, DWC, includes banking details for Abu Dhabi Commercial Bank, and features signatures from both parties.
Dubai licensing documents confirm that Aeroparts AOG DWC-LLC is engaged in trading aircraft spare parts and components, with Imad El Eddine Mohamed El Halabi as the company manager, registered in the Aviation District, Dubai.
European Interest does not assert that Imad El Eddine Mohamed El Halabi, Aeroparts AOG, or RAMC have been found by any court, regulatory authority, or sanctions body to have violated sanctions or engaged in unlawful conduct. The referenced documents illustrate commercial aviation transactions involving Aeroparts AOG, RAMC, and Russian aviation-related entities since February 2022.
The RAMC documents contain an invoice dated 7 January 2025, addressed to S7 Engineering LLC at Domodedovo Airport for aircraft parts, including seals and bushings, valued at $30,070. Earlier documents show transactions involving Russian entities; for example, a RAMC invoice dated 27 September 2022, to Siberia Airlines JSC lists parts valued at $70,957.40. An Aeroparts AOG invoice from 25 August 2022, also addressed to Siberia Airlines JSC, indicates Moscow Domodedovo Airport as the shipping address. The freight documentation names S7 Engineering LLC as the consignee and outlines the routing from Dubai World Central to Sheremetyevo via Malé, with Aeroflot noted on the air waybill.
Additionally, a contract dated 18 January 2023, identifies Sky Asia Technics LLC, based in Bishkek, Kyrgyzstan, as the contractor and S7 Engineering LLC as the customer, concerning the repair of aircraft parts and equipment. While the contract does not imply wrongdoing, it is relevant to EU concerns about technical service routes involving Russian operators.
The material indicates that Russian aviation-linked entities have frequently appeared in commercial documentation from companies in the UAE, Jordan, and Kyrgyzstan since February 2022. However, it does not clarify if the goods were of Western origin, subject to EU, UK, or US export controls, or if licenses were required or obtained. Addressing these questions would require customs records, end-use documentation, payment trails, and formal responses from the companies involved.
The structure of the aviation supply chain complicates matters, as aircraft parts are often traded through brokers, involving multiple parties and jurisdictions. This complexity raises compliance concerns when Russian end-users are involved, especially in sectors subject to export controls.
The sanctions against Kyrgyzstan highlight a broader EU policy shift. The EU is increasingly targeting third-country channels it believes are diverting restricted goods to Russia. The European Commission’s anti-circumvention tool aims to limit the sale and transfer of sanctioned goods to these high-risk countries.
While much of the aviation material pertains to the UAE and Jordan, it raises questions about the effectiveness of sanctions if Russian end-users continue to appear in suppliers’ commercial records outside Russia. The available documents do not establish a coordinated network or intent to violate sanctions, but they warrant further examination by regulatory authorities. If Russian airlines can still acquire parts and repair services through third countries, it challenges the effectiveness of the sanctions imposed after Russia’s invasion of Ukraine. It raises concerns about enforcement in global supply chains.
