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Arbitration Recognition of foreign decisions
AIFC Court sets aside Naftogaz recognition order against Gazprom for lack of jurisdiction
Introduction In a decision dated 7 July 2026, the Court of First Instance of the Astana International Financial Centre in case number AIFC-C/CFI/2026/0002, National Joint Stock Company “Naftogaz of Ukraine” JSC v Gazprom PJSC, rendered a judgment on the AIFC Court’s jurisdiction to recognise and enforce a foreign-seated ICC arbitral award. Justice Lord Faulks KC […]
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Arbitration Recognition of foreign decisionsAIFC Court at a crossroads: Naftogaz v Gazprom, Posco v National Centre, and the limits of recognition jurisdiction
In our earlier analysis, “Clash of jurisdictions – AIFC Court recognises an ICC award despite opposing Russian anti-arbitration injunction”, we discussed the AIFC Court’s 15 May 2026 decision in National Joint Stock Company “Naftogaz of Ukraine” JSC v Gazprom PJSC, Case No. AIFC-C/CFI/2026/0002. The case was remarkable not only because of the size of the […]
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Recognition of foreign decisionsRecognition of Austrian Cost Orders in Russian Insolvency Proceedings – Arbitrazh Court of Kalmykia, 21 April 2026 (A22‑1431/2016)
1. Introduction On 21 April 2026, the Arbitrazh Court of the Republic of Kalmykia ruled on the recognition and enforcement in Russia of a cost decision issued by the Regional Court of Innsbruck (Landesgericht Innsbruck, Austria) in favour of a Russian creditor, Elena Nikolaevna Baturina, against a Russian debtor, Viktor Nikolaevich Baturin, who was already […]
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Arbitration Recognition of foreign decisionsSuspicion of control by sanctioned entities is not enough to avoid payment under coal supply contract – says ICC Tribunal – Moscow Arbitrage court grants enforcement
Introduction On 15 May 2026, the Moscow Arbitrazh Court rendered a decision in case No. А40-332538/25-68-2153, granting enforcement of an arbitral award rendered on 18 September 2025 by a Tribunal under the auspices of the International Court of Arbitration of the International Chamber of Commerce (ICC) in Paris (Case No. 27933/ELU). The decision addresses the enforcement of […]
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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 […]
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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 […]
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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 […]
