Introduction The transnational dispute between Russia’s EuroChem North-West-2 and Italy’s Tecnimont, with parallel proceedings involving English, Russian and Indian courts, has become a showcase for the growing complexities of cross-border enforcement and the friction between diverging legal regimes. At stake are not only billions in contractual claims but also substantial questions about the reach of […]
Die Themen
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 […]
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 […]
Arbitrator biased: Paris CoA sets aside investment treaty award due to arbitrator’s firm’s published „no-Russia“ policy and media likes
Cour d’appel de Paris, France, 15 January 2026, RG 22/19397
Introduction: On 15 January 2026, the Paris Court of Appeal (Cour d’appel de Paris, Pôle 5 – Chambre 16) issued a decision annulling a partial arbitral award rendered under the auspices of the Permanent Court of Arbitration (PCA, Case No. 2019-34). The dispute involves the expropriation of Crimean real estate assets following Russia’s occupation of […]
BGH confirms: An application for confirmation of the scope of an arbitral clause can be filed even if proceedings on the merits are already pending in a state court: BGH, 6 November 2025, I ZB 33/25
Case Summary and Background The dispute decided by BGH on 6 November 2025 (case ref: I ZB 33/25) arose from a complex international supply relationship involving ship engines. In 2007, a German manufacturer sold four ship engines to an Australian company, I. Ltd., which installed them in the vessel “E.”. Over time, the ship changed […]
Federal Court of Justice (BGH) on the Setting Aside and Remittal of Arbitral Awards to the Original Tribunal for Re-Consideration
Introduction:In another rare decision on the setting-aside of an arbitral award, issued on 18 December 2025 (Case No. I ZB 42/25), the German Federal Court of Justice (Bundesgerichtshof, BGH) considered the appeal against the ruling by the Bavarian Supreme Regional Court (BayObLG, case no. 102 Sch 39/24 e), on which we had commented here. The […]
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 […]