Read our Governance whitepaper and explore why governance is important for the success of any business Read now


A standout statement from a business aviation conference in November 2022: “time kills deals, indictments kill deals”.

In the same month, the United States Secretary of State, Antony Blinken, issued a press release targeting Russia’s global military procurement network and Kremlin-linked networks. Within the press statement were mentions of Malta and Russia-based aircraft management company Emperor Aviation Ltd, which Blinken says has coordinated luxury travel for Kerimov’s immediate family even after Russia launched its full scale invasion of Ukraine. They also identified as blocked property eight luxury aircraft operated by Emperor Aviation.

In response to Moscow’s unprovoked war against Ukraine, the United States has been very specific about imposing high costs on President Putin’s enablers. The press release from Secretary of State Blinken is awfully specific in saying ‘Businesses worldwide are advised to do their due diligence in order to avoid being targeted for sanctions.’

It is not just knowing who you are doing business with, but also who or what is on board the aircraft. In late December 2019 Carlos Ghosn was smuggled through security at Kansai International Airport in an audio-equipment box, and then loaded onto a private jet bound for Istanbul. In September 2022 there were multiple arrests for smuggling migrants into Europe by private aircraft. Each year there are reports about private jets being used as part of drug rings globally.

What can or should business aviation do?

Not getting involved with the enablers of terror and crime is the moral starting point. But to do this, business aviation must make sure that the basics are in place:

  1. Examine the individuals and corporate entities involved in a transaction together with any influencing factor
  2. Look at the flight records especially when sanctions are at play; it is vital to know who has been involved and is flying on an aircraft.
  3. Consider the possible reputational damage that could arise after the transaction has closed.
  4. Brokers or transactional parties should alert their clients if there is a high-risk client and therefore more time will be needed to collect the information and perform risk assessments.
  5. Look closely at the supply chain.
  6. Never be in a rush to close: uncovering facts after closing could means reputational and legal disaster. Slowing down a business opportunity may kill a deal, but so does time in jail!

Read the 6 challenges facing business aviation in 2023 in full here.


The information included in this article is considered true and correct at the date of publication; changes to rules and regulation made after the time of publication may impact on the accuracy of the information referenced or inferred to in this article. The information in the article may change without notice and Martyn Fiddler Aviation is in no way liable for the accuracy of any information printed or stored or in any way interpreted and used by the user. This article or the information contained in it is not provided or intended to be used as advice of any form.
If you have any doubts or would like to discuss any aspect of this article, please do not hesitate to contact one of our experts who will be happy to discuss your individual circumstance.
About the author

Heather Gordon is Legal Director at Martyn Fiddler Aviation. Heather joined the team in 2013 having previously practiced within a leading Isle of Man law ...

Contact Heather Gordon
  • Innovators in the industry
  • Dedicated team of uniquely qualified individuals
  • There's so much we can help you with.
    Talk to us today