Tag: Hague Convention

Recognition of foreign judgments Sanctions

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 […]

Arbitration EU Sanctions

No Cost Security Required from Russian Claimant Despite War and Sanctions

Hague Convention applies no matter whether actual enforcement of a cost order is possible

In a recent ruling of 15 January 2026 (case no. I ZB 53/25), the German Federal Court of Justice (Bundesgerichtshof, BGH) clarified that Russia’s ongoing war against Ukraine and the resulting sanctions regime do not affect the Hague Convention on Civil Procedure and the exoneration of Russian claimants from any security for costs. The BGH […]