As summarized in our prior post, on March 2, 2022, the US Department of Transportation (USDOT) and Federal Aviation Administration (FAA) issued prohibitions on Russian flight operations in US airspace.

On March 2, 2022, the FAA issued a Notice to Air Missions (NOTAM) that prohibited Russian airlines and operators from using US airspace.  On March 10, 2022, the FAA issued a revised NOTAM (2/2415) to clarify applicability.  The new NOTAM revised the language regarding prohibited persons from “a person who is a citizen of the Russian Federation” to “a Russian person or entity identified by the International Trade Administration’s Consolidated Screening List” (ITA CSL).

The NOTAM contains exceptions for aircraft engaged in humanitarian or search-and-rescue operations specifically authorized by the FAA, state aircraft operations granted a diplomatic clearance by the US Department of State, and aircraft experiencing in-flight emergencies.  The March 2, 2022 USDOT Notice and Order similarly contained provisions for operators to request permission for non-revenue ferry, humanitarian, and/or search-and-rescue operations, which will be considered by USDOT on a case-by-case basis.

The far-reaching USDOT and FAA restrictions apply broadly to both commercial and non-commercial operations by any aircraft with a nexus to Russia (i.e. aircraft owned, registered, operated by, leased, or controlled by, for, or for the benefit of a Russian person or entity identified by the ITA CSL).


Jennifer Trock is chair of Baker McKenzie's International Commercial Practice Group and a member of its Global Aviation Group in Washington, DC. She co-leads the Firm's unmanned aircraft systems (UAS) focus team and is the Chair of the ABA's Forum Air & Space Law. Jennifer has been recognized by Chambers USA, Aviation Regulatory – National (2007-2019) and has also received honors from Euromoney’s Guide to the World’s Leading Aviation Lawyers, Infrastructure Journal and The Washingtonian.


Alex primarily works with transportation industry clients on transactional, public policy and regulatory matters, including before the US DOT, FAA, CBP, TSA and NTSB. Alex represents domestic and foreign air carriers, airport operators, airport sponsors, technology companies and drone/unmanned aircraft system stakeholders. He has experience handling regulatory counsel for transportation industry transactions, DOT and FAA authorization matters, antitrust immunity proceedings, rulemakings and policy changes, consumer protection issues, and regulatory enforcement matters. Alex also advises on federal and state public policy and government relations.