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How to Avoid Providing “Charter Flights” with your Part 91 Aircraft

By May 17, 2020September 6th, 2022No Comments

Check the Regulations, Documents & Facts

Failure to check the details of your documents and the FAA regulations against what is happening in real life (IRL) can become expensive. The FAA may instigate an investigation or may investigate a complaint that the aircraft owner, a lessee or a management company is providing illegal charter.  Documents which were fine ten years ago when the aircraft was purchased no longer fit the facts of how the aircraft is operated and the FAA discovers that invoices sent by the accounting department do not comply with the documents or the regulations.

Sweat the Regulatory Fine Print

The FAA has proposed a civil penalty of $3.3 million and the DOJ has filed suit against an aircraft owner over its aircraft timeshares. In the UK, an illegal charter flight arranged for a soccer player crashed and brought attention to the worldwide problem of illegal charter, which has increased governmental focus on illegal charter, whether intentional or inadvertent.

Get a Check-Up for your Aircraft Documentation

If it has been a while since you checked your aircraft documentation, do some research on:

  • Passengers on each flight
  • Purpose of each flight – business or personal & for which entity’s business
  • Invoices for each type of flight (the accounting department is not familiar with FAA regulations & new personnel may have unknowingly made changes which violate FAA regulations)
  • Documentation you have for the aircraft – do those leases and timeshares match the facts

Please contact Jetstream Aviation Law if we can assist you in addressing your aviation issues.

Michelle M. Wade is a partner with the law firm of Jetstream Aviation Law and counsels clients on the acquisition, financing and operation of corporate jets operated under Part 91 and Part 135 of the Federal Aviation Regulations. Jetstream Aviation Law can be found at


The information provided here is not legal advice and does not purport to be a substitute for advice of counsel on any specific matter. For legal advice, you should consult with an attorney concerning your specific situation.

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