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Arbitration Recognition of foreign decisions SanctionsAssignment of an ICC Award in Russia – the golden route to enforcement
Sverdlovsk court rejects sanctions, sham-transaction and tribunal-composition objections in a dispute over an assigned supply receivable and allows the enforcement of an assigned claim.
- 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 […]
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 […]
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 […]
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 […]
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 […]
