Introduction:In a recent decision delivered on 2 April 2025, the Bavarian Supreme Regional Court (BayObLG case no. 102 Sch 39/24) set aside an arbitral award in a high-profile dispute concerning milestone-based earn-outs in the life sciences sector. This ruling marks an important clarification on the requirements for due process (rechtliches Gehör) and the standard of […]
Category: Arbitration
Arbitration Restrictions Challenged Before EU Courts
Introduction Two parallel actions for annulment have been filed before the European General Court, challenging specific provisions within the European Union’s sanctions framework targeting Russia. Cases T-655/25 and T-640/25 seek to invalidate newly introduced restrictions on the recognition and enforcement of arbitral awards related to EU sanctions measures. Image by Marc Schneider from Pixabay Legal […]
Piercing the Corporate Veil: Siemens AG and its Russian subsidiary held subsidiarily liable for debts of Russian Spin-Off in Landmark Judgment by Russian Court
The St. Petersburg Arbitrazh Court has held Siemens AG and its former Russian subsidiary subsidiarily liable for the debts of OOO (Russian LLC equivalent) “Neftegaz i Energetika”, marking a landmark insolvency judgment amid sanctions and contested restructuring. © unsplash, Sasun Bughdaryan I. Introduction On 21 August 2025, the Arbitrazh Court of Saint Petersburg and Leningrad […]
Is there a successful path for enforcement of an arbitral award in Russia?
In one of our recent articles (see here), we discussed a case in which the Russian commercial court refused to recognise an arbitral award because it was requested by a foreign company from a so-called unfriendly country without a domestic bank account. Enforcement would result in a violation of the provisional public order. Now, the […]
Arbitrators and Counsel face € 7.5 bn fine by Russian Court in case of continuation of arbitration proceedings
On 9 September 2025, the Moscow Arbitration Court published its full decision on the application for an injunction prohibiting any continuation or maintenance of the arbitration proceedings in relation to Wintershall Dea. This will be examined in more detail below. I. Introduction On 9 September 2025, the Moscow Arbitrazh Court published its full decision on […]
Are even domestic arbitration awards not good enough for enforcement in Russia?
In a series of decisions (Court case no. А43-27728/2024) originating at the Arbitrazh Court in Nizhny Novgorod, a domestic Russian award in favour of a Swiss entity was first recognised and then this decision was lifted by the Court of Appeal and the matter referred back to the first instance court, which then refused enforcement […]
Russian Court issues injunction against Claimant, Arbitrators and Counsel in Energy Treaty dispute
Russia acts not only against foreign parties, but also against counsel and arbitrators
On 29 April 2025, the Moscow Arbitrazh Court (Case Number: А40-92702/25-56-674) granted a motion applied for by the General Prosecutor’s Office of the Russian Federation for interim relief, ordering the suspension of all arbitration procedures in the case of Wintershall Dea GmbH v. Russian Federation. The order applies until the court issues a final ruling […]