No: The New Replacement Parts Exception Does Not Apply to Aviation

Tomorrow’s Federal Register is expected to include a new exception that permits export of replacement parts in a very broad range of circumstances. Don’t get too excited – it doesn’t apply to aviation.

The summary of the new exception reads like this:

“The Department of the Treasury’s Office of Foreign Assets Control (OFAC) is amending its regulations in multiple sanctions programs to add general licenses authorizing certain transactions of nongovernmental organizations and certain transactions related to the provision of agricultural commodities, medicine, medical devices, replacement parts and components, or software updates.”

federalregister.gov/d/2022-27639

But when you get into the regulatory language, it is clear that the replacement parts provision only applies to replacement parts for medical devices.

I did not want anyone from our community to see the title or the summary and think it applies to aviation.