Hidden AOC Risk Checklist

Mandatory Guidance for All CanAm Staff During ACMI Operations


Purpose of This Checklist

This checklist exists to prevent Hidden AOC violations during ACMI operations with USC GmbH Frankfurt. A Hidden AOC situation arises when a non-AOC holder is perceived by authorities to be exercising operational control over flights.

Hidden AOC violations are treated as serious regulatory breaches and can result in:

  • Immediate suspension of ACMI approvals
  • Enforcement action against both partners
  • Forced operational shutdown
  • Mandatory early AOC application under pressure

This checklist is not optional.


Core Rule (Memorize This)

CanAm controls the market.
USC GmbH Frankfurt controls the aircraft.

If an action touches flight safety, dispatch, crew, or airworthiness, it is not a CanAm action.

1. Absolute Prohibitions

(These Actions Are Never Allowed)

CanAm staff must never:

  • Give instructions to flight crew
  • Give instructions to dispatch
  • Approve or reject aircraft dispatch
  • Approve MEL items or deferrals
  • Influence fuel uplift decisions
  • Influence flight planning or routing
  • Decide whether a flight operates for safety reasons
  • Communicate directly with aviation authorities on operations
  • Sign any document implying operational responsibility
  • Refer to CanAm as the “operator” in any context

If any of the above occurs, stop immediately and escalate.



2. Language and Communication Rules

(This Is Where Most Violations Happen)

Forbidden Language

CanAm staff must not use phrases such as:

  • “Our aircraft”
  • “Our crew”
  • “We operate this flight”
  • “We decided to fly”
  • “We delayed the flight for technical reasons”

Mandatory Language

Use instead:

  • “The aircraft operated by USC GmbH Frankfurt”
  • “The operating carrier has decided”
  • “According to the operator”
  • “USC dispatch confirmed”

Language discipline is legally relevant.


3. Branding and Disclosure Compliance

At all times, ensure:

  • All tickets show:
    CanAm Airways – operated by USC GmbH Frankfurt
  • Websites clearly identify the operating carrier
  • Charter contracts include operator disclosure
  • Airport signage reflects the operating carrier
  • Delay and disruption notices reference USC as operator

Missing or unclear disclosure is a regulatory red flag.


4. Crew Interaction Rules

CanAm staff may:

  • Coordinate commercial service standards
  • Discuss catering quality
  • Handle passenger issues

CanAm staff must not:

  • Brief crew on operational matters
  • Request operational deviations
  • Discuss safety, duty time, or MELs
  • Interfere with crew rest or positioning decisions

Crew reports exclusively to USC GmbH Frankfurt.


5. Maintenance and Technical Boundaries

CanAm staff may:

  • Monitor contract performance
  • Track aircraft availability
  • Enforce lease return conditions

CanAm staff must not:

  • Approve maintenance actions
  • Request technical work
  • Challenge airworthiness decisions
  • Access maintenance records beyond contractual scope

CAMO and maintenance authority remain solely with USC.


6. Dispatch and Operations Control

CanAm staff may:

  • Receive operational updates
  • Assess commercial impact
  • Adjust passenger communication

CanAm staff must not:

  • Participate in dispatch decisions
  • Suggest alternate routings
  • Request fuel or payload changes
  • Override operational decisions

Dispatch authority lies exclusively with USC.


7. Crisis and Irregular Operations

In disruptions:

  • USC decides if and how a flight operates
  • CanAm manages passenger communication and care
  • CanAm never announces operational causes independently
  • All technical explanations must come from USC

CanAm may say:

“The operating carrier has advised of a delay due to operational reasons.”

Nothing more.


8. Ownership-Specific Restrictions

(If CanAm Owns the Aircraft)

Even as aircraft owner, CanAm staff must:

  • Act exactly as if CanAm did not own the aircraft
  • Never reference ownership in operations
  • Never request operational decisions “as owner”
  • Never audit safety decisions during ACMI

Ownership gives asset rights, not operational rights.


9. Escalation Rule

If a CanAm staff member is:

  • Asked to make an operational decision
  • Pressured to intervene
  • Unsure whether an action crosses a boundary

They must:

  1. Stop
  2. Escalate internally
  3. Refer the matter to USC GmbH Frankfurt

No exceptions.


10. Internal Control Measures

CanAm enforces compliance through:

  • Mandatory staff training
  • Written acknowledgment of this checklist
  • Periodic internal audits
  • Immediate corrective action if violations occur

Repeated or intentional violations are grounds for removal from role.


11. One-Line Summary for Daily Use

If it affects safety, legality, or aircraft movement, it is not our decision.

Final Note

Hidden AOC risk is not theoretical.
It is one of the most common reasons ACMI partnerships fail.

This checklist exists to:

  • Protect CanAm
  • Protect USC GmbH Frankfurt
  • Protect the AOC transition plan

Strict adherence is mandatory.