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 […]
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Is 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 […]
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 […]
Cyprus court decision not recognised in Russia
Since 1984, Cyprus was one of the few EU countries to have concluded a mutual legal assistance agreement with Russia in civil and criminal matters, under which the two countries undertook to recognise the decisions of each other’s courts (Art. 23). However, current practice is such that this provision is no longer applied. Decisions by […]
Are even domestic arbitration awards not good enough for enforcement in Russia?
In a series of decisions (Court case no. А43-27728/2024) originating at the Arbitrazh Court in Nizhny Novgorod, a domestic Russian award in favour of a Swiss entity was first recognised and then this decision was lifted by the Court of Appeal and the matter referred back to the first instance court, which then refused enforcement […]
Is there or is there no reciprocity for the recognition of judgements between Russia and Germany?
A while ago we had reported on a decision of the Arbitrazh Court in St. Petersburg which had recognised a German court decision from Stuttgart on the basis of reciprocity – see here: Is there suddenly reciprocity regarding recognition of commercial judgements between Germany and Russia? – Koch Boës – Rechtsanwälte. Not unawaited, this decision […]
Jurisdiction Clauses Can Close the Door – Lessons from a German-Russian Dispute
When entering into international contracts, parties often agree in advance which courts should resolve any disputes that may arise. While this approach offers predictability and legal certainty, it can also severely limit a party’s options. While it is a common approach to avoid foreign jurisdictions, one might learn that a decision from one’s „home“ courts […]