Head of Legal Affairs, Aviation Leasing Division | Bank of Communications Financial Leasing

Hu Sang
Head of Legal Affairs, Aviation Leasing Division | Bank of Communications Financial Leasing
Team size: Five
What are the most significant cases, projects and/or transactions that you and/or your legal team have recently been involved in?
The Aviation Legal Affairs Department of BOCOM Financial Leasing Co., Ltd. is a specialised legal team embedded within the Company’s Aviation Leasing Department. The team is engaged daily in all legal and compliance aspects related to aviation leasing throughout the lifecycle of each transaction, including provision of support for PRC domestic and international projects such as aircraft sale and purchase, aircraft leasing (including operating leases and finance leases), lease extensions or early terminations, contract management, and handling risk mitigation tasks, including participation in bankruptcy proceedings of domestic and international airline clients and commercial litigation against airline clients. The team also manages global compliance matters such as anti-money laundering, sanctions, and export control regulations, as well as the procurement of domestic and international legal services. In addition, we support the Dublin-based legal team of our subsidiary with routine work.
As part of the business department that holds more than 300 aircraft and ranks tenth globally in aviation leasing portfolios, we cover the entire Asia and Oceania region, from the Middle East to the Asia-Pacific. Each year, we assist the Company in closing extensive deals involving the introduction of more than 20 aircraft and numerous sale or lease amendments.
In 2021, the aviation legal team participated in the innovative structuring of two Boeing 737-800 passenger-to-freighter conversion projects with China Post Airlines. This was the first full-process passenger-to-freighter operating lease project in the history of Chinese-funded leasing enterprises. The project won two major awards from globally renowned aviation finance publications and conferences: the ‘Structured Lease Deal of the Year’ at AirFinance Journal 2020 and the ‘Editor’s Deal of the Year’ in the Asia-Pacific region at Airline Economics 2021.
The team was awarded three China Business Law Journal In-House Team Awards in 2025, including Winner in International Sanctions and Compliance. I personally received three individual In-House Awards, including for International Sanctions and Compliance, Banking and Financing, and Aviation, Shipping and Logistics.
How do you approach managing legal aspects during periods of instability or crisis to ensure the organisation’s resilience?
Aviation leasing, as part of asset financing or banking business, is unique and distinctive, and many legal research institutes establish separate awards or research initiatives for aviation law. Aviation leasing is traditionally extremely ‘transactional’, but during the COVID pandemic it became one of the most severely affected industries. I always tell my team that contracts and clauses should be reviewed with a litigation perspective, particularly in China, where we were educated in a civil law system. Although aviation leasing litigation remains rare in China, embedding this uncommon approach in the contract negotiation stage allows us to handle the majority of issues that may arise during the lease term, which usually exceeds ten years.
Together with our risk and technical teams, we have also drafted contingency plans for urgent matters and crises. Our practices have evolved over the years in response to global sanctions and geopolitical conflicts, noting that aviation parts and aviation operations are both affected by export control or sanctions, and we have therefore established a process to verify compliance requirements.
Have you had any experiences during your career as a lawyer that stand out as particularly unique or interesting?
Yes, I practised independently during 2018–2019, and this experience likely makes me the first person in the aviation leasing business in China to have worked in-house for an airline, in-house for a leasing company, and as an aviation lawyer. These diverse professional experiences allow me to adopt a more flexible perspective in this business and readily propose feasible solutions. I was selected to serve on the arbitrator panels of the Shanghai International Arbitration Center and the Shanghai International Aviation Court of Arbitration, which attests to my skills in dispute resolution. I endeavour to share my experience and perspectives with my team in daily work, and I would confidently say that the team is one of the best in-house aviation teams in China.
Given the current geopolitical shifts and growing uncertainties around international free trade, has your company’s risk profile evolved, and are you taking measures to address these challenges?
As mentioned above, aviation was one of the most severely impacted businesses during COVID, and in recent years by export controls and sanctions. We have acquired deep knowledge in managing day-to-day operations while addressing new regulations as they are issued. We have established a process to verify the relevant compliance requirements.
The most important measure in facing any challenge is always to strengthen oneself and remain knowledgeable.