On 3 July 2026 the Eleventh Arbitrazh Court of Appeal (case no. A55-10205/2026) has issued a noteworthy decision on the application of Articles 248.1 and 248.2 of the Russian Arbitrazh Procedure Code (APC RF) – known as “Lugovoy Law“. In its judgment, the court set aside an order of the Arbitrazh Court of the Samara […]
Category: Sanctions
AIFC 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 […]
Clash 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 […]
A state cannot be insulted – says the German Supreme Court
Federal Court of Justice (Bundesgerichtshof, BGH), Judgment of 24 February 2026 – Case No. VI ZR 415/23
The Kingdom of Marokko failed with a claim against a publisher who had alleged that Marokko was using “Pegasus” surveillance software. The German Supreme Court held that a souverain state does not have title to sue in a defamation claim. 1. Overview of the Decision In its judgment of 24 February 2026, the German Federal […]
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 […]
Three 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 […]
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 […]