RE: Value2 Jun 2026 10:02
@Crossley. Your comment re SAS prompted me to do an AI search which came up with;
Castlelake didn’t actually “get around” the EU ownership rules. Instead, the SAS rescue was deliberately structured so that EU investors retained effective control of the airline, even though Castlelake became the largest single shareholder.
Under the restructuring announced in 2023:
* Castlelake (a US investment firm) received about 32% of the equity.
* The Danish state received about 26%.
* Air France-KLM received 19.9%.
* Danish investor Lind Invest received 8.6%.
* The remainder went to certain creditors.
Adding up the EU-owned stakes:
* Danish state: ~25.8%
* Air France-KLM: 19.9%
* Lind Invest: 8.6%
* Other largely European creditors: ~13.6%
This meant that well over 50% of the equity remained in European hands, satisfying the EU requirement that an EU airline be majority owned and effectively controlled by EU nationals.
There’s another important point: EU airline rules are not just about percentage ownership; they are also about “effective control.” Regulators look at board representation, voting rights, governance arrangements, and who can direct the airline’s strategy. The German competition authority specifically described the SAS transaction as involving non-controlling minority shareholdings by the consortium members.
So although Castlelake held the largest individual stake and a large portion of the convertible debt, it was not structured as a takeover by a US investor. Rather, it was a consortium recapitalisation in which European investors collectively maintained majority ownership and control.
Interestingly, this was always viewed as potentially temporary. In 2025, Air France-KLM announced plans to buy Castlelake’s and Lind Invest’s stakes, which would raise Air France-KLM’s holding to about 60.5%, while the Danish state would retain roughly 26%. That would leave SAS unquestionably under EU ownership and control.
In short: Castlelake never owned more than 50%, never had sole control, and was part of a wider consortium specifically designed to keep SAS compliant with EU airline ownership rules.
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