Personally, I have an idealogical problem with SFAR 77. I can't see where the FAA feels it has the right to tell us where we can or cannot go outside of the US. To me, it's just another "Nanny" Law. The government's way of protecting me from my stupid self.
You don't understand how the organization that grants you your flying privileges can regulate them? Really?
You have no flying rights. You have privileges, and you have them only insofar as the organization that grants them shall allow.
Private aircraft are operating in and out of Bagdad every day these days. Besides, the safest place in that country is probably right there on that airport. Sure there's risk involved, but no more than when we fly into places like Jakarta or Angola.
Spoken like someone who has no experience operating in Iraq.
I operated in and out of Baghdad and a number of other locations throughout Iraq last year. I enjoyed numerous mortar and rocket attacks, and other events, to say nothing of frequent encounters with unmanned traffic.
I saw no private aircraft operating. I saw contract aircraft operating which had authorization based on specific operational needs.
I flew into Baghdad as a commercial passenger, and flew in and out operationally. I've been stuck due to rocket attacks shutting down runways, including craters that prevented takeoff. Safest place in the country, you say? Compared to what? What other places in the country have you been, flying, or living?
Iraq is a fairly civil place today compared to what it was a few years ago, but it's not a safe place by any stretch of the imagination.
As for flying in and out of Afghanistan, which I do, it's hardly an easy place to arrange or operate either...and is most definitely not safe. Upon landing at a particular location there a month ago, my first notification upon coming to rest was of holes in the back of the airplane, that weren't there when we took off.
I have been associated with operations in Iraq, including recently, in which we would have loved to operate our own equipment in and out of the country to move parts, people, and equipment. Even for an organization with authorization to be there and an operational need, obtaining authorization to use our own aircraft in and out held obstacles, and often the most simple, economic solution was to commercial people in, and ship equipment.
You're far better off taking your people to Frankfurt or where ever else you find convenient, and having them commercial to their destination. Good luck moving around the country when they arrive.