Shedding Light on the Gray Market by NBAA

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Difference between Legal and Illegal Charters is difficult to Define

FAA has made detection of Gray Charters a Priority

NBAA podcast sheds light on the distinctions


Illegal or Gray Market Charters are an area of considerable FAA focus and fraught with very complex rules which differentiate between what is permitted and an operation which may result in FAA civil or criminal actions. The distinctions are fine and difficult to discern.

Past posts have explored this thicket (see below), but NBAA has published the attached podcast in which the discussion among the three speakers explore these parameters:

Gray Charters become a Federal Case

FAA $3.3 M civil penalty catalyst for warning

Red Flags for Charter Consumers

FAA Dragnet on the Gray Market

Softening Illegal Charter Compliance may not be justified

FAA $3.3 M civil penalty catalyst for warning

Here is the very illuminating podcast from NBAA

Tackling the Growing Issue of Illegal Charter Operations


May 13, 2019

Failing to address the issue of illegal charter can be a costly mistake for companies and business aircraft operators. “The FAA has provided for business aircraft, some very narrow, limited exemptions. A lot of people understand the terms and the concepts, but they’re very often misapplied because they’re very narrow” said David Norton, partner and head of the aviation practice at the law firm of Shackelford, Bowen, McKinley & Norton, LLP. Learn more about avoiding illegal charter in this week’s NBAA Flight Plan podcast.

David Norton






Elizabeth Vasseur-Browne of Cooling & Herbers also participated in the Podcast.









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