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Recognition of foreign decisionsThree days notice is not sufficient for a EUR 3.6bn claim – French Court of Appeal refuses recognition of German court order in the Uniper-Gazprom Export dispute
Enforcement Refused: Versailles Appeal Court Applies Brussels I Recast to German Seizure Order—A Procedural Review Introduction On 8 January 2026, the Cour d’appel de Versailles addressed the enforcement in France of a German court order authorizing the seizure of claims payable by Engie to Gazprom at the request of Uniper Global Commodities SE. The ruling […]
- Arbitration Investment Arbitration Recognition of foreign decisions
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 […]
- Recognition of foreign decisions
Russian Court Recognizes Latvian Bankruptcy Ruling on Trademarks: A Remarkable Decision Amidst an Anti-Western Climate
IntroductionIn an environment characterized by increasing legal isolation and skepticism towards judgments from Western or so-called “unfriendly” countries, a recent ruling by the Moscow Arbitrazh Court (Case No. A40-300609/2024, published on 11 November 2025) stands out. The court confirmed the recognition of a Latvian court decision impacting high-value international trademarks, even as diplomatic relations between […]
- Recognition of foreign decisions
Is Volkswagen AG insolvent? In Russia, it is!
Introduction In recent years, cross-border insolvency and asset recovery against multinational corporations with involvement in Russia have taken on new complexity. A landmark decision by the Moscow Arbitrazh (Commercial) Court in October 2025, opening local insolvency (bankruptcy) proceedings against the German parent company Volkswagen Aktiengesellschaft (Volkswagen AG), exemplifies these developments. This article examines the case, […]
- 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 […]
