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Wintershall Dea – Round 3: The Moscow – Dubai Arbitration Clash – the Russian Federation is in contempt of court
The Wintershall Dea Saga is continuing and in its “third round” now. This time, the geographical scope is further expanded, and old problems are addressed with a renewed strategy. We have already covered the development that Russian courts have awarded claims of more than EUR 7.5bn against counsel, arbitrators and Wintershall Dea itself (read more […]
Arbitration Investment ArbitrationArbitrator biased: Paris CoA sets aside investment treaty award due to arbitrator’s firm’s published “no-Russia” policy and social media likes
Introduction: On 15 January 2026, the Paris Court of Appeal (Cour d’appel de Paris, Pôle 5 – Chambre 16) issued a decision annulling a partial arbitral award rendered under the auspices of the Permanent Court of Arbitration (PCA, Case No. 2019-34). The dispute involves the expropriation of Crimean real estate assets following Russia’s occupation of […]
- Arbitration Maritime Industry
BGH confirms: An application for confirmation of the scope of an arbitral clause can be filed even if proceedings on the merits are already pending in a state court: BGH, 6 November 2025, I ZB 33/25
Case Summary and Background The dispute decided by BGH on 6 November 2025 (case ref: I ZB 33/25) arose from a complex international supply relationship involving ship engines. In 2007, a German manufacturer sold four ship engines to an Australian company, I. Ltd., which installed them in the vessel “E.”. Over time, the ship changed […]
- Arbitration
Sanctions-Related 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 […]
- Recognition of foreign decisions Arbitration
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 […]
Arbitration Recognition of foreign decisionsIs 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 […]
- Arbitration Recognition of foreign decisions
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 […]
