On March 18, the US Department of Commerce (DOC), through the Bureau of Industry and Security (BIS), issued a notice identifying 99 Boeing and one Gulfstream G650ER aircraft that it says have recently flown into Russia.

The statement says these aircraft have apparently violated US Export Administration Regulations (EAR) and warned anyone against providing any unauthorized form of service to them

The US message is loud and clear - don't touch these aircraft

US Secretary of Commerce Gina M. Raimondo said the department is demonstrating the power and reach of the actions being taken in response to Russia's war against Ukraine, adding,

"We are publishing this list to put the world on notice-we will not allow Russian and Belarusian companies and oligarchs to travel with impunity in violation of our laws."

The Gulfstream is listed as owned or operated by Russian oligarch and Chelsea Football Club owner, at least for now, Roman Abramovich.

Airlines named as owners or operators on the list of Boeing aircraft are Aeroflot, AirBridge Cargo, Aviastar-TU Airlines, Azur Air, Nordwind Airlines and Utair.

Azur Air Russian Airlines
Photo: Getty Images.

With things changing quickly in Russia, the DOC issued an updated list on March 30, adding another 73 Boeing aircraft. New airlines on the list are Alrosa, Atran, NordStar Airlines, Pegas Fly, Pobeda, Rossiya Airlines, RoyalFlight and S7 Airlines.

It also removed 12 aircraft off the list to allow them to be returned to owners located outside Russia. However, the Gulfstream G650, registration LX-RAY, is still sitting at the head of the DOC's list.

So, today, there are 160 aircraft (one aircraft was counted twice with the US and Russian tail number) that the DOC is clearly telling the world not to touch. The DOC statement makes that quite clear,

"Absent authorization, any person anywhere-including within Russia-risks violating the EAR and would be subject to BIS enforcement actions which could include substantial jail time, fines, loss of export privileges, or other restrictions."

If Russia keeps the aircraft flying domestically will the sanctions bite?

While the statement is clear, it seems that those within Russia are not too fussed by it. A check on flightradar24.com soon reveals that many of the listed aircraft are happily flying domestic routes within Russia.

It appears that the aircraft being used have all been reregistered with RA- numbers, such as the Boeing 737-800 that was once VP-BQB but now goes by the name of RA-73225.

Pobeda 737 Vnukovo
Aeroflot Group airline Pobeda has 20 Boeing B737-800s on the US list of sanctioned aircraft. Photo: Getty Images

Yesterday it flew from Yekaterinburg to Moscow as Pobeda DP406 and returned, perhaps refueled by someone now at the risk of jail in the US.

With Russia's airlines staying within the country and re-registering the aircraft it wants to keep, it seems that the tough talk and sanctions are not causing much concern in Moscow.

On March 22, Aeroflot announced it would be resuming flights to Sri Lanka on April 8, with their booking platform denoting a Boeing 777 as the aircraft to operate the flight. The DOC lists 19 Aeroflot B777 as subject to its sanctions, including the six reregistered with Russian tail numbers.

And yet a few days ago, Sri Lanka's state-run carrier, Sri Lankan Airlines, announced it was suspending its flights indefinitely from Colombo to Moscow.

It's hard to see that Russia will use the aircraft to leave its territory, and it's also hard to see how the US sanctions will bite while the aircraft fly domestically. There's plenty more to unfold in this saga.