On 27 January 2026, the Arbitrazh Court of the Republic of Buryatia ordered U.S.-based VTS Aviation LLC to refund USD 81,200 paid as an advance under a 2020 supply contract to JSC Ulan-Ude Aviation Plant, a subsidiary of the sanctioned Russian Helicopters holding – despite the contract containing an ICC arbitration clause providing for dispute […]
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High Court of Singapore Confirms Termination of Arbitration Due to Sanctions imposed on the Claimant
Introduction In a decision rendered on 9 February 2026 [2026] SGHC 32, the Singapore High Court rejected an application to set aside the order of a SIAC tribunal terminating an arbitration because the claimant could not continue the proceedings due to sanctions. The case confirmed the tribunal’s obligation to terminate an arbitration when continuation becomes […]
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 […]
Germany’s New Arbitration Court for Nazi-Looted Cultural Property: Key Procedural Features
On 1 December 2025, Germany’s institutional arbitration body for Nazi-looted art commenced operations, replacing the former Advisory Commission. For the first time, victims of National Socialist persecution and their legal successors have access to a formalised and legally binding procedure. Below are some of the key procedural features of the arbitration body for Nazi-looted art. […]
Waiting for the Bombay Court – Will there be a freezing order to enforce a Lugovoy-Law decision?
Indian court seized with interim application order, but no final decision yet
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 […]
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 […]