🤖 𝗙𝗶𝗿𝗲𝗱 𝗼𝘃𝗲𝗿 𝗗𝗲𝗲𝗽𝗦𝗲𝗲𝗸 𝗱𝗮𝘁𝗮 𝘂𝗽𝗹𝗼𝗮𝗱. It seems that the case of Remizova v. EnergoPof LLC is the first case in Russia in which an employee was fired, among other reasons, for uploading confidential information to DeepSeek.

The court of first instance's judgment dated 26 May 2026, in Russian, is attached.

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𝗗𝗼 𝘀𝗮𝗻𝗰𝘁𝗶𝗼𝗻𝘀 𝗼𝘃𝗲𝗿𝗿𝗶𝗱𝗲 𝗮𝗿𝗯𝗶𝘁𝗿𝗮𝘁𝗶𝗼𝗻 𝗰𝗹𝗮𝘂𝘀𝗲𝘀 𝗶𝗻 𝗥𝘂𝘀𝘀𝗶𝗮? 𝗟𝗶𝗸𝗲𝗹𝘆 '𝘆𝗲𝘀,' 𝗯𝘂𝘁 𝘁𝗵𝗲𝗿𝗲 𝗶𝘀 𝗻𝗼 𝘀𝘁𝗿𝗮𝗶𝗴𝗵𝘁 𝗹𝗶𝗻𝗲 𝘁𝗼 𝘁𝗵𝗲 𝗮𝗻𝘀𝘄𝗲𝗿 𝘀𝗼 𝗳𝗮𝗿.

In Case No. A56-113018/2025, a Russian entity, disregarding an LMAA arbitration clause, brought a legal action against two Russian entities. By its ruling dated 28 May 2026, the court of first instance referred the parties to the agreed forum. The court held that (1) the claimant was not listed on any sanctions list, and (2) there was no evidence that the defendants, despite being included on the UK sanctions list, would face obstacles in accessing arbitration.

The court of appeal overturned the court of first instance's ruling. By its ruling dated 22 July 2026, the court of appeal held that, since the defendants are included on the UK sanctions list, this creates objective obstacles to accessing arbitration; consequently, the dispute is subject to the exclusive jurisdiction of the Russian courts. The court of appeal's ruling may be subject to cassation review.

Recently, in Case No. A43-34213/2023, a Russian court, by its ruling dated 28 June 2026, upheld an LMAA arbitration clause in a case brought by a Cyprus-based entity. The court held that neither party to the dispute had been included on any sanctions list. The ruling dated 28 June 2026 has been appealed; the hearing date has not yet been set.

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𝐋𝐚𝐰𝐲𝐞𝐫 𝐅𝐢𝐧𝐞𝐝 𝐟𝐨𝐫 𝐔𝐬𝐢𝐧𝐠 𝐀𝐈. A court decision, in Russian, dated 2 July 2026, in Case No. A45-5305/2023, is another one in which a lawyer was fined for contempt of court — the lawyer cited court decisions that had never existed and were allegedly hallucinated by AI. 🤖

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𝗥𝘂𝘀𝘀𝗶𝗮𝗻 𝗖𝗼𝘂𝗿𝘁 𝗘𝗻𝗳𝗼𝗿𝗰𝗲𝘀 𝗜𝗖𝗖 𝗔𝘄𝗮𝗿𝗱, 𝗥𝗲𝗷𝗲𝗰𝘁𝘀 𝗣𝘂𝗯𝗹𝗶𝗰 𝗣𝗼𝗹𝗶𝗰𝘆 𝗮𝗻𝗱 𝗦𝗮𝗻𝗰𝘁𝗶𝗼𝗻𝘀 𝗢𝗯𝗷𝗲𝗰𝘁𝗶𝗼𝗻𝘀. In Case No. A60-26002/2026, a decision dated 24 July 2026, a Russian court issued a writ of execution for an ICC arbitral award rendered in an arbitration seated in Moscow and held:

1. An assignment of a claim under a foreign trade supply contract from a Dutch assignor to a Russian assignee does not, in itself, violate Russian public policy and does not fall under the Russian counter-sanctions measures.

2. Refusing enforcement of an award on public policy grounds requires two cumulative elements: a breach of the fundamental principles of the Russian legal system, and the occurrence of harmful consequences — damage to sovereignty, to the interests of large social groups, or to constitutional rights. The respondent failed to prove any such consequences.

3. The argument that the tribunal was improperly constituted (a sole arbitrator instead of the three provided for in the contract) was rejected on estoppel grounds: having failed to object to the tribunal's composition at the ICC case management conference, the respondent forfeited the right to raise this ground at the enforcement stage.

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🇷🇺 🇳🇬 𝗥𝘂𝘀𝘀𝗶𝗮𝗻 𝗖𝗼𝘂𝗿𝘁 𝗥𝗲𝗳𝘂𝘀𝗲𝘀 𝗘𝗻𝗳𝗼𝗿𝗰𝗲𝗺𝗲𝗻𝘁 𝗼𝗳 𝟮𝟬𝟬𝟴 𝗡𝗶𝗴𝗲𝗿𝗶𝗮𝗻 𝗝𝘂𝗱𝗴𝗺𝗲𝗻𝘁 𝗮𝘀 𝗧𝗶𝗺𝗲-𝗕𝗮𝗿𝗿𝗲𝗱. In Case No. A40-37908/2024, a Russian court, by its decision dated 31 July 2026, refused recognition and enforcement of a court judgment issued by a Nigerian court in 2008. The court held that the application for recognition had been filed after expiry of the time limit for such an application. Article 246 of the Russian Arbitrazh Procedure Code provides that a foreign court judgment may be submitted for compulsory enforcement within a period not exceeding three years from the date it entered into legal force.

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🇷🇺 🇰🇿 𝐅𝐨𝐫𝐞𝐢𝐠𝐧 𝐂𝐥𝐚𝐢𝐦𝐚𝐧𝐭𝐬 𝐍𝐨𝐭 𝐄𝐱𝐞𝐦𝐩𝐭: 𝐑𝐮𝐬𝐬𝐢𝐚𝐧 𝐂𝐨𝐮𝐫𝐭𝐬' 𝐉𝐮𝐫𝐢𝐬𝐝𝐢𝐜𝐭𝐢𝐨𝐧 𝐎𝐯𝐞𝐫 𝐒𝐚𝐧𝐜𝐭𝐢𝐨𝐧𝐬 𝐃𝐢𝐬𝐩𝐮𝐭𝐞𝐬. If the subject matter of the dispute arose from unilateral sanctions, a Russian court has exclusive jurisdiction over the dispute even if the claimant is a foreign person, the cassation court said in Case No. A40-27279/2026, in its decision dated 4 August 2026.

The cassation court disagreed with the lower courts, which had referred the parties to LCIA arbitration on the ground that the claimant, a Kazakh person, is not a sanctioned person. The cassation court did not take into account this criterion (whether the person is sanctioned), but instead considered whether the subject matter of the dispute arose from unilateral sanctions. As long as this criterion is met, the Russian court has jurisdiction over the dispute.

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🇷🇺🇫🇮 𝐑𝐮𝐬𝐬𝐢𝐚𝐧 𝐂𝐨𝐮𝐫𝐭 𝐒𝐞𝐧𝐝𝐬 𝐅𝐢𝐧𝐧𝐢𝐬𝐡 𝐂𝐥𝐚𝐢𝐦𝐚𝐧𝐭 𝐭𝐨 𝐈𝐂𝐂 𝐆𝐞𝐧𝐞𝐯𝐚. In Case No. А56-48889/2026, a Russian court, by its decision dated 14 August 2026, referred the parties to ICC arbitration in Geneva.

A Finnish company had brought legal action before a Russian court despite the arbitration clause, arguing that the clause was incapable of being performed due to restrictive measures (sanctions) against the defendant, a Russian company. The defendant requested that the court refer the parties to arbitration.

The court granted the motion, holding that no evidence had been provided to the court that the restrictive measures affected the claimant, and that no evidence had been presented indicating the existence of obstacles to the claimant's access to justice.

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🇷🇺🇨🇳 𝗥𝘂𝘀𝘀𝗶𝗮𝗻 𝗮𝗻𝗱 𝗖𝗵𝗶𝗻𝗲𝘀𝗲 𝗖𝗼𝘂𝗿𝘁𝘀 𝗥𝗲𝗮𝗱 𝗔𝗿𝘁𝗶𝗰𝗹𝗲 𝟭𝟳 𝘁𝗵𝗲 𝗦𝗮𝗺𝗲 𝗪𝗮𝘆.

In 2023, a Russian court ordered a Chinese company to pay a Russian company approximately CNY 5 million.

In 2024, the Russian company sought recognition and enforcement in China of the Russian court decision issued against the Chinese company.

The Russian Federation and the People's Republic of China are parties to the Treaty on Judicial Assistance in Civil and Criminal Matters (signed in Beijing on June 19, 1992), which, among other things, governs the recognition and enforcement of court decisions.

According to Article 17 of the Treaty, an application for recognition and enforcement must be submitted to the court that rendered the decision. That court is then responsible for transmitting the decision to a court in the other Contracting Party's country. If the applicant has a domicile or place of residence in the territory of the Contracting Party where the decision is to be enforced, the application may also be submitted directly to the court of that Contracting Party.

The Russian company submitted its application directly to a Chinese court. In doing so, the Russian company argued that it was "domiciled in China," as it owned 50% of the shares in the debtor.

The Changzhou Intermediate People's Court and the Jiangsu Higher People's Court dismissed the Russian company's motion. The courts held that the conditions under Article 17 of the Treaty were not met, and that the application for recognition and enforcement had to be submitted to the court that had rendered the decision — i.e., to the Russian court that had issued the decision.

As one can note, Chinese courts take a similar approach to Russian court decisions as Russian courts take to Chinese decisions. In Case No. A56-120092/2023, a Russian court held that an application for recognition of a Chinese court decision in Russia must be filed with the court in China that rendered the decision, which then transmits it to the competent Russian authority. 🐉

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🇷🇺Updates on Enforcement in Russia (August 13 – 18)

🇧🇾 A court has recognized and enforced, in full, a decision of the Economic Court of Gomel Region (Belarus) (Case No. A09-4726/2026). The debtor, an individual, was held liable for a Belarusian LLC's tax debt to the Belarusian state budget in the amount of 740,497.95 Belarusian rubles.

🇧🇾 A court has refused to recognize and enforce a decision of the Economic Court of Vitebsk Region (Belarus) (Case No. A56-11041/2026). The court held that under the 2001 Russia–Belarus agreement on the mutual enforcement of court acts, decisions of Belarusian economic courts are directly enforceable in Russia via a writ of execution, without a separate court recognition procedure — so the application itself was superfluous, and it was refused on that basis rather than on the merits of the underlying debt.

🇧🇾 A court has refused to recognize and enforce a decision of the Economic Court of the city of Minsk (Belarus) (Case No. A41-50140/2026). The claim was time-barred: the three-year deadline for presenting the foreign decision for enforcement in Russia had expired back in 2020, and the claimant did not request that the missed deadline be restored.

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🇷🇺 Updates on Enforcement in Russia (September 3 – 7)

🇰🇿 A court has recognized and enforced a decision of the Specialized Interdistrict Economic Court of Karaganda Region (Kazakhstan) ordering a Russian company to pay a fine and court costs (Case No. A56-60862/2026).

🇰🇿 A court has recognized and enforced a decision of the Specialized Interdistrict Economic Court of Zhambyl Region (Kazakhstan), obtained by the Zhambyl division of Kazakhstan Railways against two Russian companies (Case No. A40-349568/2025).

🇬🇧 A cassation court has upheld a lower court's refusal to recognize and enforce arbitral awards of the London Court of International Arbitration (LCIA) ordering RUSAL and RTI Limited to jointly pay roughly EUR 250 million to OWH SE i.L., a German bank in liquidation (Case No. A21-4252/2026). Both courts found that enforcing an award in favor of an entity from an "unfriendly" state would conflict with Russia's public policy under its sanctions and counter-sanctions framework.

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🇷🇺🇧🇾🇦🇪🇬🇧🇮🇱 A Belarusian entity has asked a Russian court to challenge a UK arbitrator appointed by DIAC in an ad hoc arbitration against an Israel-based entity.

The case, A40-257679/2026, is scheduled to be heard on 30 October 2026.

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🇷🇺🇨🇳 𝑹𝒖𝒔𝒔𝒊𝒂𝒏 𝑪𝒐𝒖𝒓𝒕 𝑨𝒄𝒄𝒆𝒑𝒕𝒔 𝑫𝒊𝒓𝒆𝒄𝒕 𝑨𝒑𝒑𝒍𝒊𝒄𝒂𝒕𝒊𝒐𝒏 𝒇𝒐𝒓 𝑹𝒆𝒄𝒐𝒈𝒏𝒊𝒕𝒊𝒐𝒏 𝒐𝒇 𝑪𝒉𝒊𝒏𝒆𝒔𝒆 𝑪𝒐𝒖𝒓𝒕 𝑱𝒖𝒅𝒈𝒎𝒆𝒏𝒕 𝑼𝒏𝒅𝒆𝒓 𝑨𝒓𝒕𝒊𝒄𝒍𝒆 17 𝒐𝒇 𝒕𝒉𝒆 𝑹𝒖𝒔𝒔𝒊𝒂-𝑪𝒉𝒊𝒏𝒂 𝑳𝒆𝒈𝒂𝒍 𝑨𝒔𝒔𝒊𝒔𝒕𝒂𝒏𝒄𝒆 𝑻𝒓𝒆𝒂𝒕𝒚

Article 17 of the Treaty Between the Russian Federation and the People's Republic of China on Legal Assistance in Civil and Criminal Matters (signed at Beijing on 19 June 1992) (the "Treaty") provides:

''The applicant shall submit the application to the court which rendered the decision, and that court shall transmit it to the court of the other Contracting Party in accordance with the procedure provided in Article 2 of this Treaty.''

Russian and Chinese courts have already held that if an applicant disregards this Treaty rule, the application will be left without consideration (see, e.g., case No. A56-120092/2023).

Article 17 also contains an exception, which reads as follows:

''The applicant may, however, submit the application directly to the competent court of the Contracting Party in whose territory the decision is to be recognized and enforced, if he has his domicile or place of sojourn there.''

In Case No. A40-205251/25-19-1598, a Russian court — it seems for the first time — applied this exception.

A Chinese company, relying on the exception in Article 17, submitted an application for recognition and enforcement of a Chinese court's judgment directly to a Russian court, on the ground that it had a place of business in Russia.

The defendant objected and sought to have the application left without consideration.

The court granted the application.

The defendant's argument that, for the purposes of these court proceedings, the location of a legal entity is determined exclusively by the place of state registration (paragraph 2 of Article 54 of the Civil Code of the Russian Federation), was dismissed by the court because the Treaty guarantees the other Contracting Party's nationals equal access to the courts, and this guarantee cannot be artificially narrowed by the rules of domestic civil law.

Moreover, the court held that the applicant has a connection with the territory of the Russian Federation: it opened a settlement account with a Russian bank, registered with the tax authorities and obtained a tax code, and issued a power of attorney to Russian representatives.

According to the court, these facts confirm that the applicant had a "presence" within the meaning of Article 17 of the Treaty.

As a result, the court, by its decision dated 10 September 2026, recognized and enforced the Chinese court's judgment. The decision may be appealed.

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🇷🇺🇨🇳🇧🇾🇰🇿 𝗖𝗼𝘂𝗿𝘁 𝗨𝗽𝗱𝗮𝘁𝗲𝘀 𝗼𝗻 𝗘𝗻𝗳𝗼𝗿𝗰𝗲𝗺𝗲𝗻𝘁 𝗶𝗻 𝗥𝘂𝘀𝘀𝗶𝗮 (𝗦𝗲𝗽𝘁𝗲𝗺𝗯𝗲𝗿 𝟭𝟬 – 𝟭𝟳)

🇨🇳 A Russian court has recognized and enforced a decision of a Chinese court ordering a Russian company to pay roughly $569,500 plus late-payment interest to a Chinese company. The debtor argued that the court lacked jurisdiction over it and that enforcement would violate international currency-control rules; the court rejected both arguments. The debtor has filed a cassation appeal (decision dated 10.09.2026 in Case No. A40-205251/2025).

🇧🇾 A Russian court has recognized and enforced a decision of a Belarusian court imposing subsidiary liability on a Russian individual for a company's debt, payable to the Belarusian state budget. The court first restored a missed three-year enforcement deadline, finding the creditor's repeated attempts to present the writ for execution a valid excuse (decision dated 11.09.2026 in Case No. A40-259897/2026).

🇧🇾 A Russian court has recognized and enforced a decision of a Belarusian court imposing subsidiary liability on a Russian individual for a company's debt, at the request of Brest Customs, legal successor to the original claimant for part of the claim (decision dated 14.09.2026 in Case No. A40-218655/2026).

🇰🇿 A Russian court has recognized and enforced a Kazakhstan-seated award ordering a Russian company to pay a debt to a Kazakh company (decision dated 15.09.2026 in Case No. A56-86239/2026).

🇰🇿 A Russian court has recognized and enforced a decision of a Kazakh court ordering a Russian company to pay a debt to a Kazakh company (decision dated 16.09.2026 in Case No. A56-86638/2026).

🇧🇾 A Russian court has rejected objections to the recognition and enforcement of a decision of a Belarusian court ordering Avangard LLC to pay a debt to individual entrepreneur Igor Makovik. The debtor and other interested parties argued that a settlement agreement in an unrelated corporate dispute should offset the amount, but the court found that agreement had no bearing on the foreign proceeding and let the recognition stand (decision dated 17.09.2026 in Case No. A62-6255/2026).

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🇷🇺🇺🇸 𝐑𝐮𝐬𝐬𝐢𝐚𝐧 𝐂𝐨𝐮𝐫𝐭 𝐑𝐞𝐟𝐮𝐬𝐞𝐬 𝐭𝐨 𝐑𝐞𝐜𝐨𝐠𝐧𝐢𝐬𝐞 𝐚 𝐔𝐒 𝐁𝐚𝐧𝐤𝐫𝐮𝐩𝐭𝐜𝐲 𝐂𝐨𝐮𝐫𝐭 𝐃𝐞𝐜𝐢𝐬𝐢𝐨𝐧: 𝐍𝐨 𝐑𝐞𝐜𝐢𝐩𝐫𝐨𝐜𝐢𝐭𝐲 𝐚𝐧𝐝 𝐍𝐨 𝐑𝐞𝐜𝐨𝐠𝐧𝐢𝐭𝐢𝐨𝐧 𝐨𝐟 𝐈𝐧𝐭𝐞𝐫𝐢𝐦 𝐃𝐞𝐜𝐢𝐬𝐢𝐨𝐧𝐬

In Case No. A40-35982/2026, the bankruptcy trustee sought recognition and enforcement in Russia of a decision rendered by the United States Bankruptcy Court for the Central District of California on 17 November 2025 in the bankruptcy proceedings concerning individual E. In particular, the trustee requested the Russian court to:

- recognise the decision in Russia;
- give effect in Russia to the decision’s prohibition on asserting claims against the debtor; and
- recognise the trustee’s authority to act on behalf of the debtor in respect of the debtor’s assets located in Russia.

The Court’s position

1. Russia and the United States have no treaty providing for the reciprocal recognition of judgments rendered by their respective national courts, nor are they parties to a common convention governing such recognition. The Court held that the absence of reciprocity was itself contrary to Russian public policy.

2. Interim judicial acts of foreign courts — a category into which the Court placed the decision of 17 November 2025 — are not eligible for recognition and enforcement in Russia.

In sum: By a decision dated 18 September 2026, a Russian court dismissed the application for recognition and enforcement of the US court decision.

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A Russian cassation court has finally dismissed an application in which the applicant sought interim measures in support of an LCIA arbitration. The court held that the application was not duly reasoned and that the seat of the arbitration is in an "unfriendly" country. The court decision in Russian is available at the link.

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🇷🇺🇦🇲 A Russian court has refused to recognize and enforce a ruling of an Armenian court imposing an arrest on the property and funds of an individual debtor in his Armenian bankruptcy case. The court found that Russia has no treaty obligation to recognize this category of Armenian court act, and separately held that interim measures such as an asset freeze fall outside the scope of judicial assistance in any event (decision dated 16.09.2026 in Case No. A40-157026/2026).

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🇷🇺 𝐂𝐨𝐮𝐫𝐭 𝐔𝐩𝐝𝐚𝐭𝐞𝐬 𝐨𝐧 𝐄𝐧𝐟𝐨𝐫𝐜𝐞𝐦𝐞𝐧𝐭 𝐢𝐧 𝐑𝐮𝐬𝐬𝐢𝐚 (𝐒𝐞𝐩𝐭𝐞𝐦𝐛𝐞𝐫 22 – 23)

🇺🇿 A Russian court has recognized and enforced a decision of an Uzbek court ordering one Russian company to pay a debt and penalty to another, matching the original judgment's partial award of the claims (decision dated 22.09.2026 in Case No A40-2749/2026).

🇰🇿 A Russian court has recognized and enforced a decision of a Kazakh court ordering an individual entrepreneur to repay an advance payment to a Kazakhstan-based company (decision dated 23.09.2026 in Case No A41-87935/2026).

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𝗔 𝗥𝘂𝘀𝘀𝗶𝗮𝗻 𝗰𝗼𝘂𝗿𝘁 𝘂𝗽𝗵𝗲𝗹𝗱 𝗮 𝗽𝗮𝘁𝗵𝗼𝗹𝗼𝗴𝗶𝗰𝗮𝗹 𝗮𝗿𝗯𝗶𝘁𝗿𝗮𝘁𝗶𝗼𝗻 𝗰𝗹𝗮𝘂𝘀𝗲.

The clause reads as follows:

«In case of impossibility of disputes, regulations by negotiations the Parties should bring a matter into Arbitration Court of the Plaintiff’s Country. Arbitration language will be Plaintiff’s language».

The court held that the arbitration clause provides for ad hoc arbitration and, as a result, dismissed the legal action brought before it without consideration (ruling dated 3 October 2026 in Case No. A56-47049/2026).

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🇷🇺 𝐂𝐨𝐮𝐫𝐭 𝐔𝐩𝐝𝐚𝐭𝐞𝐬 𝐨𝐧 𝐄𝐧𝐟𝐨𝐫𝐜𝐞𝐦𝐞𝐧𝐭 𝐢𝐧 𝐑𝐮𝐬𝐬𝐢𝐚 (𝐎𝐜𝐭𝐨𝐛𝐞𝐫 1 – 7)

🇧🇾 A Russian court has recognized and enforced a decision of a Belarusian court ordering a Russian individual to pay a state duty to the Belarusian state budget (decision dated 01.10.2026 in Case No A40-193141/2026).

🇰🇿 A Russian court has recognized and enforced a Kazakhstan-seated award ordering a Russian individual entrepreneur to repay an advance payment plus a contractual penalty to a Kazakh individual entrepreneur following termination of a supply contract (decision dated 05.10.2026 in Case No A60-56000/2026).

🇰🇿 A Russian court has recognized and enforced a decision of a Kazakhstani court ordering a Russian company to repay an advance for defective goods plus a contractual penalty to a Kazakh mining company (decision dated 05.10.2026 in Case No A76-17660/2026).

🇺🇿 A Russian court has recognized and enforced a decision of an Uzbek court ordering a Russian company to pay roughly $134,700 to an Uzbek company's liquidation trustee (decision dated 07.10.2026 in Case No A40-196164/2026).

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🇷🇺🇨🇳By a decision dated 5 October 2026 in case No. A40-149292/2026, a Russian court recognized and enforced a judgment issued by a Chinese court.

Judging by the online case docket, the documents reached the court through the Russian Ministry of Justice rather than directly from the applicant.

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