The US Department of the Treasury's Office of Foreign Assets Control (OFAC) has designated Malta's Emperor Aviation (EMM, Malta International) for its links to Suleiman Kerimov, a Russia-based billionaire oligarch closely tied to President Vladimir Putin, and has embargied eight business jets linked to the carrier.
"Malta- and Russia-based aircraft management company Emperor Aviation has coordinated luxury travel for Kerimov's immediate family, including [daughter] Gulnara, even after Russia launched its full-scale invasion of Ukraine on February 24, 2022. Emperor Aviation was designated pursuant to Executive Order 14024 for operating or having operated in the aerospace sector of the Russian Federation economy and for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Gulnara," the OFAC explained.
The business charter operator has only a Maltese AOC. In Russia, it operates as an aircraft management company without its own AOC.
The US financial authorities identified and blocked the following aircraft connected to Emperor Aviation:
- four Global Expresses: 9H-AMN (msn 9324), 9H-ARK (msn 60011), 9H-MAO (msn 9223), and 9H-TIO (msn 9813),
- two GVI-G650s: 9H-OKO (msn 6356) and 9H-SSK (msn 6195),
- one Cessna Citation XLS+, 9H-EEA (msn 6170), and
- one Bombardier Challenger 650, 9H-SIS (msn 6050).
It is the first time OFAC has designated Malta-registered aircraft.
At the same time, however, the US Department of Treasury issued a General Licence 40C, authorising very limited transactions with sanctioned Russian aerospace companies, lessening the impact on the Maltese operator. The business charter specialist will be able to maintain the airworthiness of its eight designated aircraft as long as the transactions do not involve any sanctioned Russian financial services or persons.
The General Licence 40C exception applies solely to goods and services necessary to maintain the safety of civil aviation, can only be provided for the benefit of aircraft registered solely outside of Russia (excluding double-registered aircraft), and has to be linked exclusively to civil aviation. Even authorised transactions cannot be conducted in a way that would violate stringent financial sanctions imposed on Russia. Russian airlines are not eligible to benefit from the exceptions as it applies exclusively to the manufacturers (including UAC United Aircraft Corporation, Irkut, and Tupolev Design Bureau), lessors (GTLK - State Transport Leasing and Ilyushin Finance), and Emperor Aviation.
