SENSATION? ASG Declined to Claim €174 Million from SmartLynx

Companies listed as creditors of SIA SmartLynx Airlines and belonging to the Avia Solutions Group holding structure have declined to pursue court claims against what was once their sister company. This became known after the deadline for submitting creditor claims to the insolvency administrator expired.
In a document currently in the possession of BLACKLIST.AERO (we will not publish the full 91-page version due to the presence of personal data relating to former SmartLynx employees), companies such as FL Technics and ASG Finance DAC are listed. However, the amount of their claims is shown as zero.

Other companies belonging to the Avia Solutions Group structure — which were included in the original list of creditors submitted by SmartLynx Airlines to the Riga Court in October 2025 — are not listed at all in the current register of creditors.
For reference, the largest SmartLynx creditors within the Avia Solutions Group structure were:
• ASG Finance DAC (Ireland) – EUR 117,156,477.64
• SmartLynx Airlines (Malta) – EUR 38,830,777.26
• SmartLynx Airlines OÜ (Estonia) – EUR 12,515,456.77
• Smart Aviation Holdings SIA (Latvia) – EUR 2,298,460.11
Total: approximately EUR 174 million.
Why Such Passivity from the Largest Creditors?
How can this apparent inaction by the largest creditors be explained?
In my view, the primary reason may lie in concerns over a potential investigation by the Corporate Enforcement Authority (CEA) in Ireland into ASG’s so-called “sale” of SmartLynx.
One month ago, in a formal letter to ASG management, a group of creditors represented by BLACKLIST.AERO notified the holding company of its intention to file a complaint with the CEA regarding actions that may constitute violations of the Irish Companies Act 2014. Among the issues raised were intra-group transactions and actions potentially detrimental to creditors.
In order to formally submit creditor claims to the SmartLynx liquidator, companies within the Avia Solutions Group orbit would have been required to provide detailed substantiation of their claims, including all supporting invoices clearly demonstrating:
• what services were provided,
• on what contractual basis, and
• why SmartLynx allegedly owed substantial sums to its parent and sister companies.
These invoices could also have shed light on the pricing structure applied to services rendered within the group. This brings me back to my article, “How to Check Avia Solutions Group for Possible Fraud: Guidance for Investors.” One of the recommendations in that guide concerned precisely the examination of intra-group transactions for potential overpricing of services — a mechanism that could artificially inflate receivables and generate so-called “paper profits.” Such accounting practices could allow management to publish strong-looking financial statements suggesting that the holding company was performing exceptionally well.
Beyond scrutiny from BLACKLIST.AERO — which ASG management has publicly criticized as a “smear campaign” — these invoices might also have become key evidence in the ongoing criminal investigation being conducted by the Latvian police.
It appears that this is precisely what the holding’s management may be seeking to avoid by declining to pursue €174 million in claims — funds that SmartLynx never actually possessed and was never realistically capable of repaying.
Artem Degtiarov, Chief editor at BLACKLIST.AERO
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