Quick Reference Country Data

Aruba

Registry: Department of Civil Aviation of Aruba (DCAA) / The Registry of Aruba

Prefix: P4- Location: Caribbean Country Status: Autonomous State of Kingdom of the Netherlands

Aircraft

Weight Restrictions: 5,700kg for aircraft and 1,000kg for rotorcraft

Maximum Age: Aircraft manufactured before 1 January 1980

Aircraft Type Certificate: EASA, FAA, Transport Canada and Brazil

Typical Structure: Aruban Corporation or via Domicile

Operation

Private Use: YES

Commercial Air Transport: YES – via ICAO 83 bis agreement or an Aruban Air Operating Certificate (AOC)

Finance

Mortgage Possible? YES

Restriction Governing Mortgage Law: A right of first mortgage of Aruba is established under Aruba law. Parties can choose the law that will govern the underlying loan documentation, which is typically NY or UK law

Priority Notice: Not applicable in the case of a right of mortgage

Public Registration: YES

Deregistration Power of Attorney: YES / IDERA

Cape Town: YES

Survey Completed by

Name: Alexandria Colindres

Company: The Registry of Aruba

Email: acolindres@p4registry.com

Phone Number: +1305.471.9889

Address: 8750 NW 36 St, Suite 210, Miami, FL 33178

Austria

Registry: Austro Control GmbH Prefix: OE- Location: Austria Country Status: Republic

Aircraft

Weight Restrictions: NO

Maximum Age: NO

Aircraft Type Certificate: EASA

Typical Structure: N/A

Operation

Private Use: YES (EASA standards applied)

Commercial Air Transport: YES (EASA standards applied)

Finance

Mortgage Possible? YES, but not publicly registered

Restriction Governing Mortgage Law: Only Chattel mortgage

Priority Notice: YES, but not publicly registered

Public Registration: Operator YES, Owner, NO

Deregistration Power of Attorney: YES

Cape Town: NO

Survey Completed by

Name: Dr Andreas Grassl, ASA, Attorney at Law

Company: AviationLaw.at

Email: andreas@vref.com

Phone Number: +43 (1) 581 05 06

Address: A 1010, Vienna, Johannesgasse

Azerbaijan

Registry: Registry of the State Civil Aviation Administration of the Republic of Azerbaijan Prefix: 4K- Location: Asia Country Status: Republic

Aircraft

Weight Restrictions: N/A

Maximum Age: N/A

Aircraft Type Certificate: Certificate of Airworthiness; certificate on compliance with the environmental requirements. Foreign certificates are accepted upon recognition by the Civil Aviation Administration (CAA)

Typical Structure: N/A

Operation

Private Use: Aircraft can be operated by individuals and legal entities having an air operator certificate issued for certain fee. A person leasing aircraft in accordance with laws based on operating lease must also have an air operator certificate. The air operator certificates are issued by the CAA. Foreigners and foreign legal entities may operate aircraft in Azerbaijan upon the recognition of analogical documents issued in other countries by CAA

Commercial Air Transport: Civil aviation conducting the carriage of passengers, luggage, cargo and mail for certain fee is considered commercial civil aviation. Carriage of weapons in the part allocated for passengers in commercial aircraft is allowed only in the company of armed forces and by taking the relevant security measures

Finance

Mortgage Possible? YES

Restriction Governing Mortgage Law: Under the Azerbaijani International Private Law, in rem rights in transport means must be determined in accordance with laws of the country where the transport means are registered. Registration/recordation of security interests for foreign-registered aircraft is not required under the Azerbaijani aviation laws. In practice, however, the recordation of security interests for foreign-registered aircraft can be achieved. Under the Aviation Law, information about the aircraft mortgage is entered into the aircraft registry

Priority Notice: N/A

Public Registration: Aircraft operated from Azerbaijan must be publicly registered in the Republic of Azerbaijan and its registerability is achieved if: the owner of aircraft is the Republic of Azerbaijan or individuals or legal entities of the Republic of Azerbaijan; there is an airworthiness licence (certificate) issued in accordance with the Aviation Law or an analogical document issued by another country and recognised in the Republic of Azerbaijan and the aircraft is not registered in any other state

Deregistration Power of Attorney: A waiver of the right to revoke a power of attorney is void in the Republic of Azerbaijan. Validity or enforceability of an irrevocable power of attorney valid under a foreign law has never been challenged in Azerbaijani courts

Cape Town: NO

Survey Completed by

Name: Natavan Baghirova

Company: BM Morrison Partners LLC

Email: nbaghirova@bmlawaz.com

Phone Number: +994 12 497 19 14 / 15

Address: Villa 9, English Yard Business Centre 43, Mammad Araz Street, AZ1106, Baku, Republic of Azerbaijan

The Bahamas

Registry: The Bahamas Prefix: C6- Location: Caribbean Country Status: Parliamentary Democracy

Aircraft

Weight Restrictions: N/A

Maximum Age: N/A, but must be a type and age acceptable to The Bahamas Civil Aviation Authority (Safety Oversight Department)

Aircraft Type Certificate: FAA, EASA, Transport Canada

Typical Structure: Corporate Entity

Operation

Private Use: YES

Commercial Air Transport: YES

Finance

Mortgage Possible? YES

Restriction Governing Mortgage Law: N/A

Priority Notice: YES

Public Registration: YES

Deregistration Power of Attorney: YES

Cape Town: NO (Anticipated ratification in 2020)

Survey Completed by

Name: Llewellyn V. Boyer-Cartwright

Job Title: Attorney-Aviation Specialist

Bahrain

Registry: Bahrain Civil Aviation Affairs (BCAA) Prefix: A9C- Location: Caribbean Country Status: Kingdom

Aircraft

Weight Restrictions: N/A

Maximum Age: N/A

Aircraft Type Certificate: EASA

Typical Structure: N/A

Operation

Private Use: YES

Commercial Air Transport: YES

Finance

Mortgage Possible? YES

Restriction Governing Mortgage Law: There is no detailed law organising the mortgage of an aircraft. However, the aircraft mortgage must be approved and registered by the BCAA in order to become effective as per the Civil Aviation Law

Priority Notice: The registration of a right over the aircraft with the BCAA will automatically grant priority to the owner of such right from the date of registration of such right

Public Registration: NO

Deregistration Power of Attorney: Although the deregistration power of attorney is not required by the BCAA, original notarised copy should be submitted to the BCAA

Cape Town: YES

Survey Completed by

Name: Ahmed Rahmi

Company: Al Salam Advocates

Email: a.rahmy@alsalamadvocates.com

Phone Number: +973 77334480

Bangladesh

Registry: Civil Aviation Authority, Bangladesh (CAAB) Prefix: S2- Location: Asia Country Status: Republic

Aircraft

Weight Restrictions: NO

Maximum Age: NO

Aircraft Type Certificate: NO

Typical Structure: N/A

Operation

Private Use: YES

Finance

Mortgage Possible? YES

Restriction Governing Mortgage Law: NO

Priority Notice: N/A

Public Registration: YES

Deregistration Power of Attorney: YES

Cape Town: NO. Bangladesh ratified Cape Town in 2008, but the protocol on aircraft equipment is still not in force

Survey Completed by

Name: Barrister Al-Amin Rahman, Barrister Sarjean Rahman Lian

Company: FM Associates

Email: s.rahman@fma.com.bd

Phone Number: +88 01713061213

Address: 8750 NW 36 St, Suite 210, Miami, FL 33178

Belgium

Registry: Belgian Civil Aviation Authority Prefix: OO- Location: Europe Country Status: Federal state

Aircraft

Weight Restrictions: None

Maximum Age: None

Aircraft Type Certificate: State of Design

Typical Structure: Limited company

Operation

Private Use: YES

Commercial Air Transport: In order to operate commercial services, the operator must obtain an air operator certificate and a transport licence

Finance

Mortgage Possible? Pledges with no dispossession may be taken on Belgian registered aircraft. The Pledge gives to the financier substantially the same rights as a mortgage and it is registered in an on-line national electronic register. Financing by way of a loan coupled with a pledge is now possible in Belgium

Restriction Governing Mortgage Law: Belgian pledges are only valid if the aircraft was registered in Belgium when the pledge was created

Priority Notice: In case of enforcement of a pledge, the creditor must give notice to the debtor, to the other creditors that hold a pledge on the same aircraft (if any) and to the creditors that have eventually seized the pledged aircraft

Public Registration: Pledges are registered in the national electronic register of pledges

Deregistration Power of Attorney: Original copy to be submitted to the Belgian Civil Aviation Authority

Cape Town: NO

Survey Completed by

Name: Giulia Mauri

Company: Pierstone

Email: giulia.mauri@pierstone.com

Phone Number: +32 2 642 00 14

Brazil

Registry: Registro Aeronáutico Brasileiro – RAB Prefix: PP- / PR- / PS- / PT- / PU- Location: South America Country Status: Democratic Federative Republic

Aircraft

Weight Restrictions: N/A

Maximum Age: N/A

Aircraft Type Certificate: State of Design – to be validated by the Brazilian Civil Aviation National Agency

Typical Structure: Corporation/Limited Liability

Operation

Private Use: YES

Commercial Air Transport: YES

Finance

Mortgage Possible? YES

Restriction Governing Mortgage Law: YES

Priority Notice: YES

Public Registration: YES

Deregistration Power of Attorney: Typically executed

Cape Town: YES

Survey Completed by

Name: João Paulo Servera

Company: Veirano Advogados

Email: joao.servera@veirano.com.br

Phone Number: +55(11)2313-5911

Address: Av. Brigadeiro Faria Lima, 3477 – 16th floor, São Paulo – SP, 04538-133 – Brazil

Bulgaria

Registry: Civil Aircraft Register of Bulgaria Prefix: LZ- Location: Europe Country Status: Republic

Aircraft

Weight Restrictions: None

Maximum Age: None but airworthiness standards are to be met

Aircraft Type Certificate: EASA

Typical Structure: Limited liability company or joint stock company

Operation

Private Use: YES

Commercial Air Transport: YES

Finance

Mortgage Possible? YES, but under local law it is qualified as a pledge

Restriction Governing Mortgage Law: Arguably the aircraft mortgage (or equivalent security interest) is to be governed by the law of the country of the aircraft registration. Hence, when Bulgaria is the country of registration, any foreign law mortgage (if created at will) is usually backed up by a Bulgarian law pledge.

Priority Notice: None

Public Registration: YES

Deregistration Power of Attorney: YES, but according to the prevailing legal views it is considered revocable

Cape Town: NO

Survey Completed by

Name: Anna Saeva

Company: Saeva Law Office

Email: anna.saeva@saeva-legal.com

Phone Number: +359 885 156 739

Canada

Registry: Canadian Civil Aircraft Register maintained by Transport Canada Civil Aviation Prefix: C- Location: North America Country Status: Federal State

Aircraft

Weight Restrictions: None

Maximum Age: None

Aircraft Type Certificate: State of Design

Typical Structure: Canadian SPV (Corporate or Partnership)

Operation

Private Use: YES

Commercial Air Transport: To operate commercial services, the operator must obtain an air operator certificate and air carrier licence(s)

Finance

Mortgage Possible? YES

Restriction Governing Mortgage Law: NO

Priority Notice: IR and/or provincial registry, as applicable

Public Registration: Yes (International Registry for Cape Town Convention aircraft objects; applicable provincial registry for non-Cape Town collateral and smaller aircraft)

Deregistration Power of Attorney: IDERA

Cape Town: YES

Survey Completed by

Name: Donald G. Gray

Company: Blake, Cassels & Graydon LLP

Email: Donald.gray@blakes.com

Phone Number: +1 416 863 2750

Address: 199 Bay Street Suite 4000, Commerce Court West, Toronto, ON, M5L 1A9, Canada

The Cayman Islands

Registry: The Civil Aviation Authority of the Cayman Islands Prefix: VP-C Location: Caribbean Country Status: British Overseas Territory

Aircraft

Weight Restrictions: YES

Maximum Age: NO

Aircraft Type Certificate: FAA, Transport Canada, JAA, EASA

Typical Structure: Typically, the aircraft will be registered in the name of either a Cayman Islands exempted company incorporated with limited liability or a company incorporated elsewhere in the Commonwealth (often the British Virgin Islands)

Operation

Private Use: YES

Commercial Air Transport: YES, subject to a Cayman Islands air operator’s certificate

Finance

Mortgage Possible? YES

Restriction Governing Mortgage Law: None

Priority Notice: YES

Public Registration: YES

Deregistration Power of Attorney: YES

Cape Town: YES

Survey Completed by

Name: Matthew Stocker

Company: Conyers Dill & Pearman

Email: matthew.stocker@conyersdill.com

Phone Number: +1 345 814 7382 (o) / +1 345 925 3273 (m)

China

Registry: Civil Aviation Administration of China Prefix: B- Location: Asia Country Status: Republic

Aircraft

Weight Restrictions: N/A

Maximum Age: N/A

Aircraft Type Certificate: YES

Typical Structure: N/A

Operation

Private Use: YES

Commercial Air Transport: YES

Finance

Mortgage Possible? YES

Restriction Governing Mortgage Law: PRC

Priority Notice: YES

Public Registration: YES

Deregistration Power of Attorney: YES (not registerable)

Cape Town: YES

Survey Completed by

Name: Yi Liu

Company: Rui Bai Law Firm – Rui Bai Law Firm is an independent law firm and a member of the PwC global network of firms

Email: yi.liu@ruibailaw.com

Phone Number: +86 10 8540 4650

Address: Unit 01, 6/F, Fortune Financial Center, 5 Dongsanhuan Zhong Road, Chaoyang District, Beijing 100020 China

Columbia

Registry: Special Administrative Unity Civil Aviation Authority (UAEAC) Prefix: HK- Location: South America Country Status: Republic

Aircraft

Weight Restrictions: Aircraft with a MTOW over 363,000 kilos must obtains prior consent from the UAEAC for import purposes

Maximum Age: None, as long as the aircraft meets the airworthiness and operation criteria set out in the section 4.29.105 of Columbia Aviation Regulations

Aircraft Type Certificate: Accepted by the UAEAC from the state of manufacture of the aircraft

Typical Structure: No specific requirements

Operation

Private Use: YES

Commercial Air Transport: YES

Finance

Mortgage Possible? YES

Restriction Governing Mortgage Law: If the mortgage has been granted under a different jurisdiction, it must be in writing thus no other formalities are required. If the mortgage has been granted under Columbian Law before the entry in force of Cape Town Convention in Columbia (1 June 2017) it must have been granted by public deed.

Priority Notice: N/A

Public Registration: Any encumbrances over aircraft duly registered with the National Aeronautics Registry of the UAEAC will be enforceable before third parties under Columbia law

Deregistration Power of Attorney: DPoAs are enforceable, IDERAs are not

Cape Town: YES

Survey Completed by

Name: Bernardo Rodriguez Ossa

Company: Parra Rodriguez Abogados

Email: bernardo.rodriguez@prslaws.com

Phone Number: +57 1 376 4200

Costa Rica

Registry: Costa Rican Aeronautical Registry, National Registry Prefix: TI- Location: South America Country Status: Republic

Aircraft

Weight Restrictions: N/A

Maximum Age: N/A

Aircraft Type Certificate: Aircraft type certificate, issued by manufacturer

Typical Structure: N/A

Operation

Private Use: YES

Commercial Air Transport: YES

Finance

Mortgage Possible? YES

Restriction Governing Mortgage Law: In general, the laws of the Republic of Costa Rica will govern chattel mortgages on Costa Rican aircrafts. This includes the Commerce Code, the General Law of Civil Aviation, the Civil Code, the Civil Procedure Code, the Notarial Code (Law No.7764 of April 17, 1998), the Regulations for the Operation of the Costa Rican Aeronautical Registry, and the Regulations for the Organisation of the Public Registry of Movable Property. Even though it is accepted as a principle in civil and commercial law that the parties to any contract may state that the laws of a foreign country govern the contract, this is not necessarily recommended for mortgages on Costa Rican aircraft.

Priority Notice: YES

Public Registration: YES

Deregistration Power of Attorney: YES

Cape Town: YES

Survey Completed by

Name: Marco Solano

Company: Aguilar Castillo Love

Email: msg@aguilarcastillolove.com

Phone Number: +506 2222 3838

Address: Centro Corporativo Plaza Roble, Edificio El Pórtico, tercer piso, Escazú, San José, Costa Rica

Croatia

Registry: Croatian Civil Aircraft Register, maintained by the Croatian Civil Aviation Agency (CCAA) Prefix: 9A- Location: Europe Country Status: Republic, EU Member State

Aircraft

Weight Restrictions: None

Maximum Age: None, but subject to airworthiness requirements

Aircraft Type Certificate: EASA

Typical Structure: limited liability company, company limited by shares

Operation

Private Use: YES

Commercial Air Transport: YES

Finance

Mortgage Possible? YES, called pledge over aircraft.

Restriction Governing Mortgage Law: The law of the country of registration shall be applied regarding ownership title and other rights in rem over the aircraft

Priority Notice: N/A. The priority of mortgages over aircraft is determined according to the date and hour that the CCAA received the request for registration of mortgage. Under Croatian law, it is possible to register the so-called ‘note on priority order’ before the mortgage has been created to keep the priority order in the Croatian Civil Aircraft Register

Public Registration: YES, in the Croatian Civil Aircraft Register

Deregistration Power of Attorney: YES, but with limited effect because it can be revoked any time

Cape Town: NO

Survey Completed by

Name: Danijela Simeunović and Ana Novaković

Company: Kovaević Prpić Simeunović Law Firm LLC

Email: info@kps-law.com

Phone Number: +385 1 5576 575

Address: Šenoina 1, 10 000 Zagreb, Croatia

Czech Republic

Registry: Aircraft Registry of the Czech Republic Prefix: OK- Location: Europe Country Status: Republic

Aircraft

Weight Restrictions: None

Maximum Age: None

Aircraft Type Certificate: EASA

Typical Structure: Private

Operation

Private Use: YES

Commercial Air Transport: YES

Finance

Mortgage Possible? YES

Restriction Governing Mortgage Law: NO

Priority Notice: NO

Public Registration: YES

Deregistration Power of Attorney: YES, but revocable

Cape Town: NO

Survey Completed by

Name: Jiri Hornik

Company: Kocian Solc Balastik, law firm

Email: jhornik@ksb.cz

Phone Number: +420 224 103 316

Address: Jungmannova 24, CZ-11000 Prague, Czech Republic

Denmark

Registry: The Danish Nationality Register maintained by the Danish Transport, Construction and Housing Authority Prefix: OY- Location: Europe Country Status: Unitary State and EU Member State

Aircraft

Weight Restrictions: N/A

Maximum Age: N/A

Aircraft Type Certificate: EASA

Typical Structure: if non-EU Owner, then on lease to a Danish AOC holder

Operation

Private Use: YES

Commercial Air Transport: YES

Finance

Mortgage Possible? YES

Restriction Governing Mortgage Law: N/A

Priority Notice: NO

Public Registration: YES

Deregistration Power of Attorney: YES, but the Deregistration Power of Attorney will automatically be revoked in case of the grantor’s bankruptcy

Cape Town: YES

Survey Completed by

Name: Morten Hans Jakobsen

Company: Gorrissen Federspiel

Email: mj@gorrissenfederspiel.com

Phone Number: +45 33 41 41 41

Address: Axeltorv 2, 1609 Copenhagen V, Denmark

Dominican Republic

Registry: Instituto Dominicano de Aviación Civil (IDAC - Dominican Institute of Civil Aviation) Prefix: HI- Location: Caribbean Country Status: Republic

Aircraft

Weight Restrictions: N/A

Maximum Age: N/A

Aircraft Type Certificate: YES

Typical Structure: N/A

Operation

Private Use: YES

Commercial Air Transport: YES

Finance

Mortgage Possible? YES

Restriction Governing Mortgage Law: YES

Priority Notice: YES

Public Registration: YES

Deregistration Power of Attorney: YES

Cape Town: NO

Survey Completed by

Name: Rodolfo Mesa

Company: Mesa Abogados

Email: rmch@mesalex.com

Phone Number: +1 809 338 0444

Address: Lope de Vega No. 13, Edf. Progreso Suite No. 705, Ensanche Naco, Santo Domingo, Distrito Nacional, República Dominicana

El Savador

Registry: Registro de Aviación Civil Salvador or Salvadoran Civil Aviation Registry of El Salvador (RAS) Prefix: YS- Location: Central America Country Status: Republic

Aircraft

Weight Restrictions: None (subject to approval by the Autoridad de Aviación Civil or Civil Aviation Authority, AAC)

Maximum Age: None (subject to approval by the Autoridad de Aviación Civil or Civil Aviation Authority, AAC)

Aircraft Type Certificate: Airworthiness certificate (standard and special)

Typical Structure: Subsidiary or Branch

Operation

Private Use: YES

Commercial Air Transport: YES

Finance

Mortgage Possible? YES . Restriction Governing Mortgage law: Only applicable for aircrafts with Salvadoran licence

Priority Notice: None

Public Registration: YES, at the RAS

Deregistration Power of Attorney: Not specifically regulated under Salvador so general rule of POAs apply to this type of POA. If the POA is granted abroad, to be recognised in El Salvador, it must be duly legalised and apostilled, officially translated into Spanish and, if the attributions in the POA are of a mercantile nature (eg actions related to the lessee’s business), then the POA shall also be registered at the Salvadoran Registry of Commerce

Cape Town: NO

Survey Completed by

Name: Carolina Lazo/Vanessa Granados

Company: ARIAS

Email: Carolina.lazo@ariaslaw.com Vanessa.Granados@ariaslaw.com

Phone Number: +503 225 70900

Address: Calle la Mascota No. 533 Colonia San Benito, San Salvador, República de El Salvador

Fiji

Registry: Civil Aviation Authority of Fiji Prefix: DQ- Location: South Pacific Country Status: Independent Republic

Aircraft

Weight Restrictions: None

Maximum Age: Not specified in regulations

Aircraft Type Certificate: Airworthiness Approval Note (ANN)

Typical Structure: Aircraft can be registered by: citizens of Fiji or bodies incorporated in Fiji or non-Fiji citizens resident or carrying on business in Fiji, or bodies incorporated outside Fiji, with the prior consent of the Fiji minister for Civil Aviation

Operation

Private Use: YES

Commercial Air Transport: YES

Finance

Mortgage Possible? YES

Restriction Governing Mortgage Law: None

Priority Notice: None

Public Registration: NO, but the authority will note interest on aircraft register. The register is open to inspection by members of the public

Deregistration Power of Attorney: YES

Cape Town: YES

Survey Completed by

Name: Richard Naidu and Bhumika Khatri

Company: Munro Leys, Lawyers & Notaries Publi

Email: richard.naidu@munroleyslaw.com.fj bhumika.khatri@munroleyslaw.com.fj

Phone Number: +679 322 1816

Address: Pacific House, Butt Street, P O Box 149, Suva, Fiji

France

Registry: France Prefix: F- Location: Europe Country Status: Sovereign state (republic)

Aircraft

Weight Restrictions: None

Maximum Age: None if the aircraft has a valid – or qualifies for a – certificate of airworthiness, but registration of older aircraft such as vintage aircraft may be assessed on a case-by-case basis (airworthiness requirements)

Aircraft Type Certificate: EASA

Typical Structure: NO specific requirement, however owner must be an EU or EEA individual or corporation or, if outside of EU/EEA, the aircraft must be leased to a French AOC holder

Operation

Private Use: YES

Commercial Air Transport: YES

Finance

Mortgage Possible? YES

Restriction Governing Mortgage Law: YES, mortgage should be governed by French law

Priority Notice: N/A

Public Registration: YES, French registry is publicly available

Deregistration Power of Attorney: N/A. Under French law, powers of attorney may be revoked at any time by the grantor. Moreover, the registry is a registry of title so the owner may de-register the aircraft at any time.

Cape Town: Signed but not ratified

Survey Completed by

Name: Matthieu de Varax

Company: Odi-se Avocats

Email: mdevarax@odise.com

Phone Number: +33 1 79 35 07 50

Germany

Registry: Luftfahrzeugrolle (maintained by Luftfahrt Bundesamt LBA) Prefix: D- Location: Europe Country Status: Federal Republic

Aircraft

Weight Restrictions: None

Maximum Age: None

Aircraft Type Certificate: EASA

Typical Structure: Owner-Registry. Operator must be a European person or entity

Operation

Private Use: YES

Commercial Air Transport: YES

Finance

Mortgage Possible? Registered liens are possible. They are recorded on a separate registry (Register für Pfandrechte an Luftfahrzeugen) at district court of Braunschweig (Amtsgericht Braunschweig)

Restriction Governing Mortgage Law: German law

Priority Notice: YES

Public Registration: YES

Deregistration Power of Attorney: None

Cape Town: Signed but not ratified

Survey Completed by

Name: Kai Stucken

Company: HSP Schaefer – Schäfer Rechtsanwaltsgesellschaft mbH

Email: nfo@hsp-law.de

Phone Number: +49 511 343530

Address: Hohenzollernstr. 26, 30161 Hannover, Germany

Guatemala

Registry: National Aeronautic Registry of Guatemala Prefix: TG- Location: South America Country Status: Republic

Aircraft

Weight Restrictions: None

Maximum Age: None

Aircraft Type Certificate: Issued by manufacturer

Typical Structure: None

Operation

Private Use: YES

Commercial Air Transport: YES

Finance

Mortgage Possible? YES

Restriction Governing Mortgage Law: In accordance with Guatemalan law, the mortgage of an aircraft is perfectly feasible, and the same shall be registered in the General Property Registry. In case the guarantee only covers the engine of the aircraft, it may be encumbered through the creation of a movable guarantee and recorded in the Registry of Movable Guarantees.

Priority Notice: Duly constituted mortgage or movable guarantee encumbrances are considered preferential vis-a-vis the detention. First in time, first in right

Public Registration: YES

Deregistration Power of Attorney: YES

Cape Town: NO

Survey Completed by

Name: Natalia Callejas Aquino

Company: Aguilar Castillo Love

Email: nca@aguilarcastillolove.com

Phone Number: +502 249 57272

Address: 7ma Avenida 5-10 zona 4, Centro Financiero, Torre II, Nivel 11, oficina 1

Guernsey

Registry: Guernsey Aircraft Register Prefix: 2- Location: Europe Country Status: British Crown Dependency

Aircraft

Weight Restrictions: NO

Maximum Age: NO

Aircraft Type Certificate: EASA, FAA, Transport Canada, Brazil

Typical Structure: Body corporate, registration by individuals and unincorporated bodies is also permitted

Operation

Private Use: YES

Commercial Air Transport: YES

Finance

Mortgage Possible? YES

Restriction Governing Mortgage Law: NO

Priority Notice: YES

Public Registration: YES

Deregistration Power of Attorney: YES

Cape Town: YES

Survey Completed by

Name: Paolo Lironi

Company: 2-Reg

Email: plironi@2-reg.com

Phone Number: +44 330 828 0875

Haiti

Registry: Direction de l’Exploitation Aérienne de l’Office Nationale de L’Aviation Civile (OFNAC) Prefix: HH- Location: Carribean Country Status: Republic

Aircraft

Weight Restrictions: None

Maximum Age: None

Aircraft Type Certificate: YES

Typical Structure: NO

Operation

Private Use: YES

Commercial Air Transport: YES

Finance

Mortgage Possible? YES

Restriction Governing Mortgage Law: NO

Priority Notice: NO

Public Registration: YES

Deregistration Power of Attorney: YES

Cape Town: NO

Survey Completed by

Name: Salim Succar

Company: Lissade Law Firm

Email: ssuccar@lissadelaw.com

Phone Number: +509 3759 4449

Address: 8, rue Louissaint, Bourdon, Port-au-Prince, Haïti HT6111

Honduras

Registry: Registro Aeronáutico Nacional or National Aeronautical Registry (RAN) of the Agencia Hondureña de Aeronáutica Civil (AHAC) Prefix: HR- Location: South America Country Status: Republic

Aircraft

Weight Restrictions: None (subject to approval by the Agencia Hondureña de Aeronáutica Civil or Honduran Civil Aviation Agency)

Maximum Age: None (subject to approval by the Agencia Hondureña de Aeronáutica Civil or Honduran Civil Aviation Agency)

Aircraft Type Certificate: Not specified

Typical Structure: None

Operation

Private Use: YES

Commercial Air Transport: YES

Finance

Mortgage Possible? YES

Restriction Governing Mortgage Law: Those established in the article 232 et seq. of the Civil Aviation Law

Priority Notice: None

Public Registration: National Aeronautical Registry (RAN) of the Agencia Hondureña de Aeronáutica Civil (AHAC)

Deregistration Power of Attorney: YES

Cape Town: NO

Survey Completed by

Name: Mario Aguero

Company: Arias

Email: aguero@ariaslaw.co

Phone Number: +505 2221 4505

Address: Blvd. Morazán, Centro Comercial El Dorado, Sixth Floor. Tegucigalpa, Hondura

India

Registry: Directorate General of Civil Aviation (DGCA) Prefix: VT- Location: Asia Country Status: Republic

Aircraft

Weight Restrictions: NO

Maximum Age: YES – 18 years for pressurised aircraft, 20 years for unpressurised

Aircraft Type Certificate: YES, issued by ‘Contracting State’

Typical Structure: Company limited by shares

Operation

Private Use: YES

Commercial Air Transport: YES

Finance

Mortgage Possible? YES

Restriction Governing Mortgage Law: None

Priority Notice: YES

Public Registration: YES

Deregistration Power of Attorney: YES

Cape Town: YES

Survey Completed by

Name: Karan Singh Chandhiok

Company: Chandhiok & Mahajan, Advocates and Solicitors

Email: karan.chandhiok@chandhiok.com

Phone Number: +91 11 4163 0033

Address: C - 524 Defence Colony New Delhi - 110024 India

Indonesia

Registry: Indonesia Prefix: PK- Location: Asia Country Status: Republic

Aircraft

Weight Restrictions: None

Maximum Age: YES, depending on aircraft weight categories

Aircraft Type Certificate: YES

Typical Structure: None

Operation

Private Use: YES

Commercial Air Transport: YES

Finance

Mortgage Possible? NO

Restriction Governing Mortgage Law: None

Priority Notice: None

Public Registration: None

Deregistration Power of Attorney: IDERA

Cape Town: YES

Survey Completed by

Name: Afriyan Rachmad, Louise Patricia Esmeralda

Company: Roosdiono & Partners (a member of ZICOlaw)

Email: afriyan.rachmad@zicolaw.com louise.patricia@zicolaw.com

Phone Number: +6221 2978 3888

Address: The Energy, 32nd Floor, SCBD Lot 11A , Jl. Jend. Sudirman Kav. 52-53, Jakarta Selatan, Indonesia 12190

Iran

Registry: The Civil Aviation Organization of Islamic Republic of Iran Prefix: EP- Location: Asia Country Status: Islamic Republic

Aircraft

Weight Restrictions: None

Maximum Age: None

Aircraft Type Certificate: YES

Typical Structure: Corporation

Operation

Private Use: YES

Commercial Air Transport: YES

Finance

Mortgage Possible? YES

Restriction Governing Mortgage Law: NO

Priority Notice: YES

Public Registration: YES

Deregistration Power of Attorney: Not mandatory

Cape Town: YES

Survey Completed by

Company: Law Offices of Dr. Hassan AMIRSHAHI & Associates

Email: info@amishahilaw.com

Phone Number: +98 21 88 31 96 72

Address: 30 Magnolia Alley, Qaem Maqam Street, Tehran 1588613917, Iran

Ireland

Registry: The Irish Aviation Authority Prefix: EI- & EJ- Location: Europe Country Status: Unitary State

Aircraft

Weight Restrictions: None

Maximum Age: None

Aircraft Type Certificate: EASA

Typical Structure: Limited company

Operation

Private Use: YES

Commercial Air Transport: YES

Finance

Mortgage Possible? YES

Restriction Governing Mortgage Law: None

Priority Notice: None

Public Registration: YES

Deregistration Power of Attorney: IDERA

Cape Town: YES

Survey Completed by

Name: James Duggan

Company: Flynn O’Driscoll Business Lawyers

Email: jamesduggan@fod.ie

Phone Number: +353 1 6424252

Isle of Man

Registry: Isle of Man Aircraft Registry Prefix: M- Location: Europe Country Status: British Crown Dependency

Aircraft

Weight Restrictions: Maximum Take-Off Mass (MTOM) 5,700kg; or 2730-5700kgs with significant economic benefit to the Isle of Man; and no weight restriction for Isle of Man residents

Maximum Age: None

Aircraft Type Certificate: Canada, USA, Brazil, EASA or its Member States

Typical Structure: Limited or Incorporated companies

Operation

Private Use: YES

Commercial Air Transport: NO

Finance

Mortgage Possible? YES

Restriction Governing Mortgage Law: Mortgaging of Aircraft Order 1972 as applied to the Isle of Man

Priority Notice: YES

Public Registration: YES

Deregistration Power of Attorney: YES

Cape Town: YES

Survey Completed by

Name: Simon Williams

Company: Isle of Man Aircraft Registry

Email: aircraft@gov.im

Phone Number: +44 1624 682358

Israel

Registry: The Civil Aviation Authority of Israel (CAAI) Prefix: 4X- Location: Middle East Country Status: Sovereign State

Aircraft

Weight Restrictions: None

Maximum Age: None

Aircraft Type Certificate: YES

Typical Structure: None

Operation

Private Use: YES

Commercial Air Transport: YES

Finance

Mortgage Possible? YES

Restriction Governing Mortgage Law: Subject to restrictions as per the fourth chapter of the Aviation Regulations (Aircraft Registration and Marking), 5734-1973

Priority Notice: NO

Public Registration: YES

Deregistration Power of Attorney: Original, notarised and apostilled copy to be submitted

Cape Town: NO

Survey Completed by

Name: Ilan Winder & Omer Guy

Company: Naschitz, Brandes, Amir & Co., Advocates

Email: ilanwinder@nblaw.com oguy@nblaw.com

Phone Number: +972 3 6235000

Address: 5 Tuval St. Tel-Aviv 6789717, Israel

Italy

Registry: ENAC (Ente Nazionale per l’Aviazione Civile – Italian Civil Aviation Authority Prefix: I- Location: Europe Country Status: Republic

Aircraft

Weight Restrictions: None

Maximum Age: Historic aircraft, defined as those manufactured before 1975

Aircraft Type Certificate: EASA

Typical Structure: Limited liability company or joint stock company

Operation

Private Use: YES

Commercial Air Transport: YES

Finance

Mortgage Possible? YES

Restriction Governing Mortgage Law: Notarised mortgage deed required

Priority Notice: NO

Public Registration: YES

Deregistration Power of Attorney: Available instrument, but self-help remedies not enforceable

Cape Town: NO

Survey Completed by

Name: Laura Pierallini, Francesco Grassetti

Company: Studio Pierallini

Email: l.pierallini@pierallini.it f.grassetti@pierallini.it

Phone Number: +39 06 8841713

Address: Viale Liegi, 28; 00198 – Rome, Italy

Japan

Registry: Ministry of Land, Infrastructure and Transport – Civil Aviation Bureau (JCAB) Prefix: JA Location: Asia Country Status: Unitary State

Aircraft

Weight Restrictions: None

Maximum Age: None

Aircraft Type Certificate: FAA/EASA

Typical Structure: Limited liability Company

Operation

Private Use: YES

Commercial Air Transport: YES

Finance

Mortgage Possible? YES

Restriction Governing Mortgage Law: All aircraft operating in Japan must be registered with the JCAB and will attract Japanese nationality. Similarly, all mortgages of such aircraft must be governed by Japanese law. A foreign law mortgage will be unenforceable

Priority Notice: NO

Public Registration: Mortgages over aircraft must be registered with the JCAB

Deregistration Power of Attorney: YES

Cape Town: NO

Survey Completed by

Name: Olivia Matsushita, Masao Kasatsug

Company: Pillsbury Winthrop Shaw Pittman Foreign Law Enterprise

Email: olivia.matsushita@pillsburylaw.com masao.kasatsugu@pillsburylaw.com

Phone Number: +81 3 6268 6710

Address: 20th Floor, Marunouchi Eiraku Bldg., 4-1, Marunouchi 1-chome, Chiyoda-ku, Tokyo 100-0005 Japan

Jersey

Registry: Jersey Aircraft Registry (JAR) Prefix: ZJ- Location: Europe Country Status: British Crown Dependency (not part of United Kingdom)

Aircraft

Weight Restrictions: None

Maximum Age: None

Aircraft Type Certificate: USA (FAA), Canada (Transport Canada), states represented by EASA. Registry may consider others. Registration of aircraft engines (including commercial aircraft engines) is also permitted

Typical Structure: Body corporate. Registration by individuals and unincorporated bodies is permitted. Only bodies corporate and individuals resident in Jersey, a Commonwealth country, Guernsey, Isle of Man, an EEA country or Switzerland may register aircraft on the JAR (no equivalent restriction for aircraft engines)

Operation

Private Use: YES

Commercial Air Transport: NO

Finance

Mortgage Possible? YES

Restriction Governing Mortgage Law: None

Priority Notice: YES

Public Registration: YES

Deregistration Power of Attorney: YES

Cape Town: NO

Survey Completed by

Name: James Willmott and Peter German

Company: Carey Olsen Jersey LLP

Email: james.willmott@careyolsen.com peter.german@careyolsen.com

Phone Number: +44 (0)1534 822 307, +44 (0)1534 822 372

Address: 47 Esplanade, St Helier, Jersey JE1 0BD, Channel Islands

Jordan

Registry: Aircraft National Register maintained with the Civil Aviation Regulatory Commission Prefix: JY- Location: Middle East Country Status: Constitutional monarchy with elected parliament

Aircraft

Weight Restrictions: None

Maximum Age: YES

Aircraft Type Certificate: FAA, ANAC, TCCA, EASA.

Typical Structure: Body corporate. Registration by individuals is permitted

Operation

Private Use: YES

Commercial Air Transport: YES

Finance

Mortgage Possible? YES

Restriction Governing Mortgage Law: Mortgage of an aircraft must be registered at the Aircraft National Register

Priority Notice: None

Public Registration: YES

Deregistration Power of Attorney: IDERA

Cape Town: YES

Survey Completed by

Name: Khaled Asfour

Company: Ali Sharif Zu’bi Advocates and Legal Consultants

Email: khaled.asfour@zubilaw.com

Phone Number: + 962 79 841 5555

Address: 14 Ibn Al-Faredh Street, near Jordan Hospital, Amman, Jordan

Kenya

Registry: Kenya Civil Aviation Authority Prefix: 5Y- Location: Africa Country Status: Republic

Aircraft

Weight Restrictions: None

Maximum Age: None

Aircraft Type Certificate: FAA, EASA , TCCA , ANAC, UK CA

Typical Structure: LLC

Operation

Private Use: YES

Commercial Air Transport: YES

Finance

Mortgage Possible? YES

Restriction Governing Mortgage Law: NO

Priority Notice: YES (if registered under Cape Town)

Public Registration: NO

Deregistration Power of Attorney: YES

Cape Town: YES

Survey Completed by

Name: Suzanne Muthaura

Company: MMAN Advocates

Email: smuthaura@mman.co.ke

Lithuania

Registry: Civil Aircraft Registry of the Republic of Lithuania Prefix: LY- Location: Europe Country Status: Republic

Aircraft

Weight Restrictions: None

Maximum Age: None

Aircraft Type Certificate: EASA

Typical Structure: LLC

Operation

Private Use: YES

Commercial Air Transport: YES

Finance

Mortgage Possible? YES

Restriction Governing Mortgage Law: NO

Priority Notice: YES

Public Registration: YES

Deregistration Power of Attorney: YES (but not IDERA)

Cape Town: YES

Survey Completed by

Name: Giedrius Stasevicius

Company: Ellex Valiunas

Email: giedrius.stasevicius@ellex.lt

Phone Number: +370 5 2681847

Address: Jogailos st. 9, 01116 Vilnius, Lithuania

Luxembourg

Registry: Direction de l’Aviation Civile (DAC) Prefix: LX- Location: Europe Country Status: Sovereign State (Grand-Duchy)

Aircraft

Weight Restrictions: None

Maximum Age: None

Aircraft Type Certificate: EASA

Typical Structure: None

Operation

Private Use: YES

Commercial Air Transport: YES

Finance

Mortgage Possible? YES

Restriction Governing Mortgage Law: YES

Priority Notice: YES

Public Registration: YES

Deregistration Power of Attorney: YES

Cape Town: YES

Survey Completed by

Name: Frédéric Gervais

Company: Novalaw-GJP

Email: Frederic.gervais@novalaw-gjp.lu

Phone Number: +352 26 26 43 1

Address: 10, Boulevard Royal, L-2449 Luxembourg

Malta

Registry: Civil Aviation Directorate Prefix: 9H- Location: Europe Country Status: Repubic

Aircraft

Weight Restrictions: Minimum weight of 20kg

Maximum Age: None

Aircraft Type Certificate: None

Typical Structure: Public LLC

Operation

Private Use: YES

Commercial Air Transport: YES

Finance

Mortgage Possible? YES

Restriction Governing Mortgage Law: NO

Priority Notice: None

Public Registration: YES

Deregistration Power of Attorney: YES

Cape Town: YES

Survey Completed by

Name: Geraldine Noel

Company: Acumum Legal & Advisory

Email: gnoel@acumum.com

Phone Number: +356 2778 1700

Address: 260, Triq San Albert, Gzira GZR 1150, Malta

Mauritius

Registry: Department of Civil Aviation Prefix: 3B- Location: Africa Country Status: Repubic

Aircraft

Weight Restrictions: NO

Maximum Age: NO

Aircraft Type Certificate: YES

Typical Structure: Company limited by shares

Operation

Private Use: YES

Commercial Air Transport: YES

Finance

Mortgage Possible? YES

Restriction Governing Mortgage Law: NO

Priority Notice: NO

Public Registration: YES

Deregistration Power of Attorney: YES

Cape Town: NO

Survey Completed by

Name: Vincent Chong Leung

Company: GlobaLex Chambers

Email: vincent@globalexchambers.com

Phone Number: +230 212 2288

Address: 201 Sterling House, 9-11 Lislet Geoffroy Street, Port Louis, Mauritius