Actually, not a single aircraft leased to Russian airlines should fly anymore. The sanctions originally stipulated that all transactions must be terminated. However, returns have only occurred in exceptional cases because the Russian government has passed laws that make it difficult for Lessors to get their property.
An enormous number of aircraft were also transferred to the aviation register of the Russian Federation without the consent of the leasing companies. This step is considered extremely controversial because there were no formal de-registrations in Ireland on the Bermuda Islands. However, the authorities have suspended the registrations. Some states that are not participating in the sanctions are refusing to allow aircraft that they consider to be “dual” registered to use their airspace.
Because of the sanctions affecting payment transactions with Russia, some carriers can no longer pay the leasing rates. The Russian government has also thought of this in order to at least maintain appearances. The funds end up in so-called C accounts, which can – at least in theory – be accessed by the lessors at any time. In practice, however, this doesn't work because it would be a violation of the sanctions and, on top of that, the money cannot be taken out of Russia. Western lessors have little or nothing to do with Russian rubles.
The EU sanctions stipulate that there is a possibility that the defacto theft of the aircraft can be legalized. In concrete terms, this means that a financial compensation for the machines can be agreed. Some lessors rely on lawsuits, sometimes also against the insurance companies, others on negotiations and still others on a mixture of both.
Aeroflot was able to reach a settlement with BOC Aviation. This extends to eight commercial aircraft that belong directly to Lessor and another that is managed. The affected machines are in use at the Pobeda subsidiary and have not yet been returned. The agreement stipulates that the insurance company NSK will pay all claims of the Irish BOC subsidiary, which formally owns the Boeing jets. Similar deals have already been concluded with SMBC, CDB Aviation and Aer Cap.