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Arbitration Recognition of foreign decisionsClash of jurisdictions – AIFC Court recognises an ICC award despite opposing Russian anti-arbitration injunction
Will Kazakhstan side with the New York Convention or recognise a Lugovoy judgement? On 15 May 2026, the Court of First Instance of the Astana International Financial Centre (“AIFC Court”) issued a judgment recognising and enforcing a USD 1.37 billion ICC arbitral award obtained by Naftogaz against Gazprom. The award itself had been rendered in […]
- Arbitration Recognition of foreign decisions
Russian Federation vs. Wintershall (almost) reloaded
On 3 April 2026, the Arbitrazh Court of the Kaluga Region issued an anti-arbitration injunction in case No. A23-9385/2025 involving JSC “Kaluga Plant Remputmash” (“RPM”) and Austrian manufacturer L. Maschinenfabrik GmbH. In application of the notorious “Lugovoy-Law” (art. 248.1 and 248.2 of the APC), the court prohibited the Austrian company from continuing or supporting arbitration […]
ArbitrationEffects of ICC award nullified by contradicting Russian Lugovoy Law judgement
In its judgment of 27 April 2026, the Arbitrazh Court of the Murmansk Region (case no. A42-2551/2025) ordered T. AG (Germany) and AS L. (Latvia) to jointly compensate damages of EUR 8.8 million to ООО “MTP Lavna”. The court held that the defendants’ refusal to return advance payments—based on EU sanctions—constituted a tortious act under […]
- Arbitration
Sanctions vs. Enforcement: Limits and Lessons from the Swiss Federal Tribunal
This decision provides essential guidance on the interaction between sanctions law and private enforcement mechanisms in Switzerland.For this, the Federal Tribunal establishes three key principles: This judgment is highly significant, as it forms part of a body of international case law recognizing the relevant claim in itself, although payment of that claim is not currently […]
- Arbitration Recognition of foreign decisions
When enforcement threatens “Russian industry”: Russian court denies enforcement of USD 6 million Luxembourg awards
The Arbitrazh Court of the Ural District refused recognition and enforcement of Luxembourg arbitration awards, reasoning, inter alia, that enforcement could “cause damage to Russian industry.” Background of the dispute The dispute arose between Giuseppe Bruzzone and Luigi Stoppani (both Italian citizens) and Koaland Investment Ltd (BVI), on the one side (collectively, the claimants), and […]
- Arbitration
No Valid Service under Private Address if the Adressee is Subject to a Travel Ban – Court of Appeal (Civil Division), 19 February 2026, [2026] EWCA Civ 139
Overview In Fridman v Agrofirma Oniks LLC & Anor , the Court of Appeal (Lewison LJ, Phillips LJ and Sir Launcelot Henderson) addressed a fundamental question of English private international law: can a claimant validly serve proceedings at a defendant’s English residence where the defendant is subject to an indefinite UK travel ban and is […]
- Arbitration
Russian Court Disregards ICC Arbitration Clause under Art. 248.1 APC RF and Orders U.S. Company to Refund Advance Payment to Russian Helicopters Subsidiary
On 27 January 2026, the Arbitrazh Court of the Republic of Buryatia ordered U.S.-based VTS Aviation LLC to refund USD 81,200 paid as an advance under a 2020 supply contract to JSC Ulan-Ude Aviation Plant, a subsidiary of the sanctioned Russian Helicopters holding – despite the contract containing an ICC arbitration clause providing for dispute […]
