When Western lessors demanded the return of over 400 commercial aircraft following Russia's invasion of Ukraine, Russia did not comply. Instead, it built a system — legal cover, maintenance workarounds, parts supply chains and third-country transit arrangements — to keep those aircraft operational indefinitely. This report maps how.
Key findings
Before February 2022, the Russian commercial aviation fleet was predominantly Western-owned and Western-financed. Approximately 515 of Russia's roughly 980 commercial aircraft were operated under international operating leases — primarily from Irish and Bermuda-registered lessors including AerCap (the world's largest aircraft lessor), Air Lease Corporation, SMBC Aviation Capital and BOC Aviation. The aircraft themselves were registered in Bermuda (VP-B prefix) or Ireland (EI- prefix), with airworthiness oversight by the Bermuda Civil Aviation Authority (BCAA) and the Irish Aviation Authority (IAA).
Following Russia's invasion of Ukraine on 24 February 2022, the EU, UK, US, Canada and other Western jurisdictions imposed export control restrictions on aviation goods and services to Russia, and prohibited continued leasing arrangements. Lessors were given a deadline — initially 28 March 2022, subsequently varied — to terminate their leases and recover their aircraft. Russia closed its airspace to Western carriers on 28 February, creating a practical barrier to aircraft recovery.
Of the approximately 515 leased aircraft, roughly 78 were successfully recovered — those that were abroad when the closure happened, or those operating on routes where recovery was feasible. The remaining 437 aircraft remained in Russia, and lessors subsequently filed insurance claims totalling approximately $8–10 billion under their war risk and political risk policies.
On 14 March 2022, Russia's Federal Assembly passed Federal Law No. 34-FZ, which authorised the re-registration of foreign-owned aircraft operating in Russia under the Russian aircraft register (RA- prefix). The law provided a domestic legal basis for Russian airlines to continue operating aircraft without the consent of their legal owners, and without the airworthiness oversight of the BCAA or IAA.
Following re-registration, the Bermuda Civil Aviation Authority and Irish Aviation Authority suspended the airworthiness certificates of all aircraft that had been re-registered without their consent. From the perspective of ICAO member states, these aircraft operate without valid ICAO-standard airworthiness documentation — meaning they cannot legally land in any jurisdiction that requires an ICAO-standard certificate of airworthiness.
This has effectively divided the world into two sets of airspace:
Russian international routes shifted substantially after February 2022. Airlines that previously flew to EU and US destinations — Aeroflot, S7, Ural Airlines, Nordwind, Rossiya — now concentrate operations on Turkey, the UAE, Egypt, Armenia, Georgia, Serbia and CIS states. These jurisdictions have not adopted coordinated international positions on Russian aviation, and continue to permit Russian carriers to operate.
The most operationally significant consequence of retaining Western-built aircraft is the maintenance problem. Boeing and Airbus aircraft require specific parts, specific maintenance procedures and — to maintain airworthiness under Western certification systems — maintenance performed by engineers certified by the European Union Aviation Safety Agency (EASA) or the FAA. These are not available in Russia under sanctions.
Russia has addressed this problem through three mechanisms, none of which is equivalent to a functioning Western-standard maintenance regime:
Russian airlines have grounded aircraft with technical issues and used them as parts donors for active aircraft. Multiple Russian aviation observers and the aviation safety publication AirCurrents have documented this practice. It is limited: a cannibalised aircraft reduces the total fleet size, and eventually the parts available from grounded aircraft are exhausted.
By mid-2025, Russian aviation safety observers estimated that a meaningful portion of the retained fleet had been effectively taken offline as parts sources — with the active fleet maintained at the expense of grounded airframes. This represents a net reduction in operational capacity even within a nominally unchanged fleet number.
Russia has authorised Russian-trained and Russian-certified engineers to perform maintenance on Western aircraft types, outside the EASA/FAA certification framework. Russian Federal Air Transport Agency (Rosaviatsia) has issued its own maintenance approvals — domestically valid but not recognised internationally. The practical quality of this maintenance is unknown to outside observers; Russian aviation authorities do not publish incident data with the transparency of Western regulators.
The risk associated with unlicensed maintenance on complex Western aircraft types — particularly for high-cycle operations with high utilisation rates — is the subject of ongoing concern among aviation safety experts. Aircraft structural and systems knowledge is well-documented in maintenance manuals and Boeing/Airbus technical documentation, but the replacement of specific parts with non-OEM equivalents introduces variables that certified Western procedures are designed to exclude.
The most consequential long-term mechanism is the procurement of genuine OEM and aftermarket aviation parts through third-country intermediaries. Aviation components — landing gear components, avionics parts, engine components, fasteners and consumables — are globally traded commodities, available through a large network of aviation parts dealers and distributors. Export controls on Russian destinations require exporters in the US and EU to prevent export; they do not directly prevent re-export from third countries.
An examination of corporate registries, export trade data and open-source intelligence identifies a consistent pattern in how aviation parts reach Russia under sanctions. The structure involves several layers:
The UAE is not subject to US or EU aviation sanctions against Russia, and its free zones — particularly the Dubai Multi Commodities Centre (DMCC), Jebel Ali Free Zone (JAFZA) and Sharjah Airport International Free Zone (SAIF Zone) — offer incorporation with minimal public disclosure requirements. Multiple trading companies incorporated in UAE free zones appear in US Bureau of Industry and Security (BIS) and OFAC enforcement actions and designation notices for aviation parts supply to Russian entities.
The pattern is consistent: a UAE-registered trading company procures parts from legitimate Western distributors (often without disclosing the end destination), then ships to a Russian airline or affiliated entity — directly or via an additional intermediary. The UAE company may be incorporated weeks before the transaction and dissolved shortly after, or maintained as a persistent procurement vehicle.
Turkey occupies a structurally similar position to the UAE: not subject to Western aviation sanctions against Russia, major aviation hub, substantial established trading infrastructure, and significant air connectivity to Russian destinations. Turkish trading companies appear in multiple reported instances of parts procurement for Russian aviation. Turkey's aviation regulator, SHGM, has continued to permit Russian-operated routes and has not joined export control coordination efforts.
Armenia, Kazakhstan, Georgia and Kyrgyzstan have each been identified in trade data and enforcement actions as transit jurisdictions for goods moving toward Russia — including aviation-related components. Kazakhstan in particular has seen a significant increase in reported exports to Russia of items subject to export controls, consistent with its role as a transit jurisdiction.
These jurisdictions are not party to Western sanctions regimes, have existing trade relationships with Russia, and have established logistics infrastructure that can accommodate goods transiting to Russian destinations.
For compliance professionals, the Russian aviation sanctions network raises several practical issues:
Aviation parts dealers, distributors and logistics providers operating in legitimate markets face exposure to Russian sanctions evasion if their goods are acquired by intermediaries who re-export to Russia. US export controls under the Export Administration Regulations (EAR) extend to re-exports of US-origin items by non-US parties. Adequate due diligence on ultimate end-users — beyond declared end-use certificates — is a compliance requirement that the Russian aviation case makes directly relevant.
Entities incorporated in UAE free zones, Turkish trading companies and Central Asian logistics providers all carry elevated sanctions evasion risk in the current environment. This does not make them per se problematic — these are major trading hubs with many legitimate activities — but it makes enhanced due diligence on counterparties in these jurisdictions a commercial necessity for any business with Russian sanctions exposure. Standard adverse media screening and sanctions list checking is not sufficient for this risk category; OSINT-based beneficial ownership analysis of the specific counterparty is required.
The insurance claims filed by Western lessors — many of whom are in active arbitration against Russia in international tribunals — represent one of the largest contested insurance events in history. For insurers, reinsurers and legal professionals involved in these matters, the documentation of the network described here — re-registration, continued operation, maintenance bypass, parts supply — is directly relevant to the quantum of loss and the attribution of responsibility.
This report is based entirely on open-source intelligence: publicly filed corporate registrations, published regulatory enforcement actions (US BIS denial orders and OFAC designations), public aviation safety reporting, ICAO documentation, international trade statistics, and published journalism from aviation specialist publications including The Air Current, Simple Flying, and major international outlets. No confidential sources were used. All findings are attributable to named public sources.
The network described here is not complete — by the nature of sanctions evasion, the full picture is not publicly visible. What is visible from open sources is sufficient to demonstrate the structural pattern. A full investigative mandate — with access to financial intelligence, corporate registry cross-referencing across all relevant jurisdictions, and benefical ownership analysis of the intermediary entities — would extend this picture substantially.
For organisations with specific exposure to this network — as counterparties, as lessors, as insurers, or as compliance functions — a confidential enquiry is the starting point for a targeted investigation.
Counterparty OSINT, beneficial ownership analysis, sanctions screening — one confidential message is enough.
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