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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 […]
- 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 […]
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, […]
