Export, Sanctions & Aviation Compliance Policy

This Policy establishes minimum controls for aviation salvage Listings, Documents, buyer access, offer review and closing workflows. It is designed for cross-border B2B operation involving the European Union, Switzerland and other jurisdictions.

The Policy does not replace legal advice, export classification, licence determination, customs advice, airworthiness review or competent-authority decisions.

Certain aviation parts, avionics, navigation equipment, aerospace components, propulsion-related items, technology, software or technical Documents may be subject to export controls. Under EU Regulation 2021/821, listed dual-use items may require authorisation, and non-listed items may also become controlled under catch-all rules in certain circumstances.

Swiss export controls administered by SECO may apply to dual-use goods, specific military goods, technology and software, including used or defective goods where listed or where catch-all concerns exist.

The Platform must not be used for transactions involving sanctioned persons, entities, vessels, aircraft, countries, territories, end-users or prohibited end-uses under applicable EU, Swiss, UN, UK, US or other relevant sanctions regimes.

Before a deal is marked sold, the Operator should maintain evidence of buyer verification, destination review, end-user/end-use review where applicable and any internal compliance approval required by the Listing status.

Listings may be assigned statuses such as pending, cleared, restricted or blocked. Pending means not yet reviewed. Cleared means no platform-level restriction has been identified based on available information. Restricted means additional review, documentation or approval is required. Blocked means publication, document release or closing should not proceed.

A cleared status is not a legal opinion, export licence, customs decision, airworthiness approval or guarantee of lawful transfer. It is an internal workflow control only.

Private Documents must be disclosed only to verified and authorised users with a legitimate transaction purpose. Export-controlled technology, sensitive claim records, chain-of-custody documents and certificates should be released only after appropriate review.

The Platform should maintain document access logs and may restrict download, revoke access, suspend users or require additional confidentiality undertakings where risk is identified.

No damaged, salvaged or removed part may be represented as airworthy solely because it appears on the Platform. Installation, return to service or resale for aviation use requires appropriate inspection, maintenance data, approved repair, authorised release documentation and compliance with applicable continuing airworthiness rules.

Buyers and repair organisations remain responsible for determining whether their approvals cover the relevant part, process, rating, work scope and jurisdiction.

The Operator should retain records of Listings, offers, buyer verification, compliance status changes, document access logs, messages, closing steps, proformas/invoices and sold status for a period consistent with legal, export-control, aviation documentation and dispute-resolution requirements.

For dual-use exports from the EU, Regulation 2021/821 includes recordkeeping obligations that may require exporters and brokers/providers of technical assistance to keep detailed records for specified periods. Parties should obtain jurisdiction-specific advice for applicable retention requirements.