A London court battle over six abandoned Airbus jets is shaping up as the latest test of how sanctions clauses hold up when an airline and a lessor can't agree on who was entitled to walk away first.
STLC Europe Eight, the Irish leasing arm of Russia's state-owned aircraft owner GTLK, has filed a High Court claim against easyJet seeking at least $72 million. The liquidators bringing the case say the budget carrier grounded six leased Airbus narrowbodies in Madrid and Cyprus back in 2022, then left them sitting on the tarmac without upkeep while storage bills piled up.
The root of the disagreement goes back to the days immediately after Russia's invasion of Ukraine. Brussels imposed sweeping aviation sanctions on 25 February 2022, restricting the supply of aircraft, parts and related maintenance, insurance and financing to Russian interests. GTLK itself was added to the EU's sanctions list on 8 April 2022, a designation GTLK's own financial disclosures later confirmed froze its foreign units out of virtually all activity, triggering an asset freeze that European courts have since found extends to subsidiaries controlled by a sanctioned parent, even ones incorporated outside Russia.
That question of "control" has already been fought over extensively in the Irish courts: in a 2025 judgment, the Irish High Court found that once GTLK Europe was placed into liquidation by court order on 31 May 2023, the presumption that it remained under Russian control was "conclusively rebutted", handing day-to-day control to independent liquidators rather than Moscow.
easyJet told STLC that same April it was terminating its leases on the six aircraft, arguing sanctions made it impossible to keep servicing or repairing them. STLC's liquidators see it differently. Their claim argues the restrictions never applied in the first place, because the jets themselves never went anywhere near Russia and the leasing company that owned them was Irish, not Russian.
Three of the jets were left at Larnaca in Cyprus. STLC's liquidators say they eventually got hold of those and sold them, but their condition after months of neglect meant they went for at least $32.5 million below what they should have fetched. The other three are still parked at Madrid and haven't been sold at all.
Add it up and the lawsuit is chasing roughly $36.7 million in unpaid rent and interest, another $32.5 million for depreciation, plus €2.8 million in outstanding airport fees — with the liquidators cautioning the final number could climb once the Madrid aircraft are actually valued and sold.
That depreciation claim is itself a small reminder of another niche corner of the market: some lessors buy residual value insurance or guarantees specifically to protect against an asset losing value faster than expected, though it's not known whether STLC held any such cover on these six jets. easyJet hasn't yet lodged a formal defence but has said publicly that it intends to fight the claim in full.
It's a case that's landed at an awkward moment for the airline, which is currently the subject of a takeover approach from private equity giant Apollo Global Management — a reminder that legacy sanctions litigation doesn't necessarily go away just because ownership changes.
For insurers and brokers working in aviation, this case is really a smaller cousin of a much bigger, ongoing argument: who absorbs the financial fallout when sanctions make it impossible to operate or recover an asset as intended? That question has already produced some of the largest awards ever handed down by the English courts.
The insurance question hiding inside easyJet's own defence. easyJet's stated reason for terminating the leases was that sanctions left it unable to maintain or repair the aircraft. But several law firms advising the leasing sector at the time flagged a related, less obvious problem: a long-standing principle in aviation insurance holds that cover automatically ceases to be effective wherever continuing to provide it would itself breach an embargo or sanction.
Holland & Knight said as much within days of the EU's sanctions taking effect, warning leasing firms to urgently review their policies. If STLC's own aviation cover was similarly affected, that raises a question quite separate from maintenance: whether the aircraft were adequately insured at all while they sat idle in Madrid and Larnaca, and who was on the hook for that gap. Most leases require the lessee to keep hull and liability insurance in place naming the lessor as an additional insured for the full lease term, a requirement that gets a lot harder to satisfy once the underlying insurer itself won't, or legally can't, keep the policy live.
Why "all risks" and "war risks" keep coming up: most hull and liability policies split cover in two. All-risks cover is broad but usually carries a political-risk exclusion; war-risks cover is narrower but was written for exactly this kind of state action. When an asset can't be recovered because of government interference rather than a conventional loss event, insurers and lessors end up arguing over which bucket the claim falls into, and that argument, more than the underlying facts, is what has driven the size of recent awards.
The most consequential of those rulings came last year, when the High Court found that a group of insurers including AIG, Lloyd's, Chubb and Swiss Re had to pay out under war-risk cover for aircraft that Russian carriers had effectively been unable to return after Moscow's own export ban made recovery impossible. That judgment secured aircraft-leasing giant AerCap just over $1 billion, among the largest sums an English court has ever awarded, and insurers were later refused permission to appeal it. Getting there wasn't cheap, either, AerCap alone reportedly ran up around £81 million in legal costs securing that result, a reminder of why litigation funding and after-the-event cover have become a live topic in disputes of this size.
Contingent cover, not just hull cover. Part of what made that AerCap ruling so closely watched was its treatment of "contingent" or "gap" cover — the backstop policy a lessor holds precisely in case the lessee's own required insurance lapses or is voided partway through a lease. The court had to work out whether lessors' "possessed cover" (for aircraft still nominally with the airline) or their contingent cover was the one that should respond once repossession became impossible. It's exactly the kind of product most people outside aviation insurance rarely think about, and exactly the kind of product that starts to matter a great deal once an aircraft ends up parked, unmaintained and in dispute for months on end, as the six Airbus jets in the easyJet case were.
A market that was already braced for this. Political risk insurance underwriters had been bracing for large losses from Russia-linked aviation exposure since the earliest days of the invasion analysts at Peel Hunt warned within weeks that Lloyd's alone could face a "sizable" hit from its share of a roughly $2 billion political risk book covering Russia and Ukraine, a figure that has since been dwarfed by the scale of claims that followed.
As Marsh's global head of aviation and space, Garrett Hanrahan, put it at the time, the exposure risked becoming "the biggest aviation insurance loss in market history" and cases like the easyJet claim are part of the long tail still working its way through the courts three and a half years on.
Other lessors caught up in the same wave of litigation have taken a different route, settling directly with insurers rather than waiting for judgment. Dubai Aerospace Enterprise, for instance, reached a settlement with AXA over a chunk of its stranded fleet rather than pursue the claim through to trial.
Not every claim in this space even makes it past the starting line without a fight over jurisdiction. A related set of proceedings saw lessors try to pursue reinsurers directly, only for the reinsurers to argue the English courts had no business hearing disputes governed by Russian law a procedural battle that shows how much of this litigation is fought before anyone even gets to the merits.
What makes the easyJet case slightly different is that it isn't really an insurance claim at all — it's a straight lessor-versus-airline dispute over who breached a contract first. But the underlying issue, whether a sanctions regime genuinely excuses non-performance, is precisely the kind of question that keeps coming up in aviation risk more broadly, and it's increasingly shaping how policies get written. The Lloyd's Market Association has already updated its standard sabotage and terrorism wording to reflect a more complex sanctions landscape, and recent market surveys have flagged geopolitical instability as a leading concern for aviation underwriters for the first time.
Whichever way the easyJet case goes, it adds to a growing body of English case law that brokers, underwriters and legal teams will be watching, not because it will move the needle on its own, but because every ruling on what counts as a lawful sanctions-driven exit helps sharpen how the next contract, and the next policy wording, gets drafted.
For UK insurers with aviation exposure to the region, the direction of travel from the courts over the past 18 months has been consistently unfavourable to anyone hoping sanctions provide a clean, uncontested exit from a contract. That's a lesson worth keeping in mind well beyond this one case.
Guidance on the UK's sanctions regime relating to Russia, including the aviation and financial restrictions referenced above, is maintained by the government at gov.uk/government/collections/uk-sanctions-on-russia.
