By: Derek Bloom
Marks & Sokolov
Rostransnadzor has commenced multiple administrative proceedings against aviation companies and is imposing fines for non-compliance Russia with passenger and crew disclosure requirements. Rostransnadzor is the shortened name of the Federal Service for Transportation Oversight, a branch of the Russian Federation Ministry of Transportation Supervision.
Russian passenger data disclosure requirements, the ACDPDP, came into effect as of December 31, 2013. The Russian business aviation community was iniitally somewhat in denial about the ACDPDP system. Thought was given initially not to the question how to comply with the ACDPDP system, but how not to comply with the ACDPDP system. Attention was given to arguments about why operators of business aircraft could not comply. Some advocated that all operators of business jets should agree not to comply with the Russian passenger information disclosure rules, there would be some safety in numbers, and the business aviation industry could take a wait and see approach. There is no longer any safety in taking a wait and see approach. Delay will lead to administrative proceedings and fines. Instead, operators should bring themselves into compliance with the passenger and crew disclosure requirements as soon as possible.