The โLugovoy Actโ has survived a second constitutional review.
The Russian Constitutional Court has published its ruling dated October 14, 2025, in which the applicant argued that articles 248.1 and 248.2 of the Russian Procedural Code, which establish the exclusive jurisdiction of Russian courts over disputes involving unilateral sanctions, are unconstitutional insofar as these articles do not authorize Russian courts to grant anti-enforcement injunctions. The Court dismissed the application.
๐ Ruling No. 2615-O dated October 14, 2025, in Russian, can be found at the link.
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The Russian Constitutional Court has published its ruling dated October 14, 2025, in which the applicant argued that articles 248.1 and 248.2 of the Russian Procedural Code, which establish the exclusive jurisdiction of Russian courts over disputes involving unilateral sanctions, are unconstitutional insofar as these articles do not authorize Russian courts to grant anti-enforcement injunctions. The Court dismissed the application.
๐ Ruling No. 2615-O dated October 14, 2025, in Russian, can be found at the link.
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๐ท๐บ๐ง๐พ On 5โ6 November 2025, a Russian court recognised and enforced:
(a) an arbitral award rendered by the International Arbitration Court at the Belarusian Chamber of Commerce and Industry (Case No.
(b) a court decision issued by a court of the Republic of Belarus (Case No.
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(a) an arbitral award rendered by the International Arbitration Court at the Belarusian Chamber of Commerce and Industry (Case No.
ะ40-237335/25);(b) a court decision issued by a court of the Republic of Belarus (Case No.
ะ40-237389/25). #BelarusProArbitration.Ru
๐๐ก๐ ๐๐ข๐ง๐ญ๐๐ซ๐ฌ๐ก๐๐ฅ๐ฅ ๐๐๐ฌ๐.
The Russian General Prosecutor brought a legal action seeking the recovery ofRUB EUR 7.5 billion as the court fine set out in the court ruling dated September 9, 2025, issued against the arbitrators and the investorโs legal counsel in the Wintershall case.
The hearing is scheduled for November 20, 2025.
๐ Case No ะ40-92702/2025.
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The Russian General Prosecutor brought a legal action seeking the recovery of
The hearing is scheduled for November 20, 2025.
๐ Case No ะ40-92702/2025.
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โค2
On November 11, 2025, Russian courts handed down three decisions dealing with the enforcement of foreign court decisions in Russia ๐ท๐บ.
๐ง๐พ The Arbitrazh Court of the Smolensk Region refused to recognise and enforce a decision issued by a court of the Republic of Belarus, finding that the defendant had not been duly notified of the proceedings (Case No. A62-97/2025).
๐บ๐ฟ The Arbitrazh Court of the Rostov Region recognised and enforced a decision issued by a court of the Republic of Uzbekistan (Case No. A53-28229/2025).
๐ฑ๐ป The Arbitrazh Court of the City of Moscow refused to block the enforcement of a court decision issued by a court of the Republic of Latvia (Case No ะ40-300609/2024). The court rejected the applicantโs reference to Russiaโs public policy, stating, surprisingly:
โBy invoking a violation of the public policy of the Russian Federation, the applicant is in fact disagreeing with the conclusions of the foreign court and challenging that courtโs assessment of the factual circumstances, which is contrary to the provisions of [a Russian procedural law].โ
#Belarus #Uzbekistan #Latvia
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๐ง๐พ The Arbitrazh Court of the Smolensk Region refused to recognise and enforce a decision issued by a court of the Republic of Belarus, finding that the defendant had not been duly notified of the proceedings (Case No. A62-97/2025).
๐บ๐ฟ The Arbitrazh Court of the Rostov Region recognised and enforced a decision issued by a court of the Republic of Uzbekistan (Case No. A53-28229/2025).
๐ฑ๐ป The Arbitrazh Court of the City of Moscow refused to block the enforcement of a court decision issued by a court of the Republic of Latvia (Case No ะ40-300609/2024). The court rejected the applicantโs reference to Russiaโs public policy, stating, surprisingly:
โBy invoking a violation of the public policy of the Russian Federation, the applicant is in fact disagreeing with the conclusions of the foreign court and challenging that courtโs assessment of the factual circumstances, which is contrary to the provisions of [a Russian procedural law].โ
#Belarus #Uzbekistan #Latvia
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๐ท๐บ ๐ฑ๐บ ๐๐จ๐ฎ๐ง๐ฌ๐๐ฅ ๐๐ข๐ญ๐ก๐๐ซ๐๐ฐ๐๐ฅ ๐๐ง๐ ๐๐จ๐ฌ๐ฌ๐ข๐๐ฅ๐ ๐
๐ข๐ง๐๐ง๐๐ข๐ง๐ ๐จ๐ ๐๐ง "๐๐ง๐๐ซ๐ข๐๐ง๐๐ฅ๐ฒ ๐๐จ๐ฎ๐ง๐ญ๐ซ๐ฒ" ๐๐ฌ ๐๐ซ๐จ๐ฎ๐ง๐๐ฌ ๐๐จ๐ซ ๐๐๐๐ฎ๐ฌ๐๐ฅ ๐จ๐ ๐ ๐๐ฎ๐ฑ๐๐ฆ๐๐จ๐ฎ๐ซ๐ -๐๐๐๐ญ๐๐ ๐๐ฐ๐๐ซ๐ ๐ข๐ง ๐๐ฎ๐ฌ๐ฌ๐ข๐
In Case No. ะ60-40234/2025, three Italian ๐ฎ๐น individuals sought recognition and enforcement of an arbitral award rendered in their favour in arbitration under the auspices of the Luxembourg ๐ฑ๐บ Chamber of Commerce (la Chambre de Commerce du Luxembourg) against a Russian ๐ท๐บ individual, a Russian ๐ท๐บ legal entity, and a Cypriot ๐จ๐พ legal entity.
The Arbitrazh Court of the Sverdlovsk Region refused recognition and enforcement of the award in Russia. Some of the courtโs reasons are rather interesting.
1. As follows from the courtโs decision, during the arbitral proceedings the legal counsel for the Russian individual, the respondent, withdrew from providing legal services to him.
The respondent asked for an extension of the time to submit its submission. The arbitral tribunal refused the motion.
Taking into account that the arbitrators were from Belgium and Luxembourg, the court held that (a) there was a lack of equal treatment of the parties, and (b) a lack of impartiality and objectivity on the part of the arbitrators.
2. Taking into account that one of the respondents โ the Russian legal entity โ has a special status (a public-interest enterprise), the court concluded that the execution of the arbitral award and the possible payment by this Russian legal entity could be considered as financing an "unfriendly country."
The court decision dated November 12, 2025, could be appealed.
๐ The case can be found at the link.
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In Case No. ะ60-40234/2025, three Italian ๐ฎ๐น individuals sought recognition and enforcement of an arbitral award rendered in their favour in arbitration under the auspices of the Luxembourg ๐ฑ๐บ Chamber of Commerce (la Chambre de Commerce du Luxembourg) against a Russian ๐ท๐บ individual, a Russian ๐ท๐บ legal entity, and a Cypriot ๐จ๐พ legal entity.
The Arbitrazh Court of the Sverdlovsk Region refused recognition and enforcement of the award in Russia. Some of the courtโs reasons are rather interesting.
1. As follows from the courtโs decision, during the arbitral proceedings the legal counsel for the Russian individual, the respondent, withdrew from providing legal services to him.
The respondent asked for an extension of the time to submit its submission. The arbitral tribunal refused the motion.
Taking into account that the arbitrators were from Belgium and Luxembourg, the court held that (a) there was a lack of equal treatment of the parties, and (b) a lack of impartiality and objectivity on the part of the arbitrators.
2. Taking into account that one of the respondents โ the Russian legal entity โ has a special status (a public-interest enterprise), the court concluded that the execution of the arbitral award and the possible payment by this Russian legal entity could be considered as financing an "unfriendly country."
The court decision dated November 12, 2025, could be appealed.
๐ The case can be found at the link.
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๐ท๐บ ๐ฆ๐ฒ On November 14, 2025, a Russian court recognized and enforced a decision issued by a court of the Republic of Armenia (Case No. ะ83-14679/2025). #Armenia
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๐ท๐บ๐บ๐ฟ In Case No. ะ82-11334/2024, the cassation court, by its decision dated November 14, 2025, upheld the lower courtโs reasoning pursuant to which the decision of a court of the Republic of Uzbekistan was recognized and enforced in Russia. #Uzbekistan
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๐น๐๐ ๐๐๐
๐๐๐๐๐ ๐๐๐ซ๐ฌ ๐ญ๐ก๐ ๐ซ๐๐๐จ๐ ๐ง๐ข๐ญ๐ข๐จ๐ง ๐จ๐ ๐ ๐๐จ๐ซ๐๐ข๐ ๐ง ๐๐จ๐ฎ๐ซ๐ญ ๐๐๐๐ข๐ฌ๐ข๐จ๐ง ๐ข๐ง ๐๐ฎ๐ฌ๐ฌ๐ข๐.
The Arbitrazh Court of the City of Moscow, acting pursuant to Article 245.1 of the Russian Arbitrazh Procedural Code, by its decision dated November 17, 2025, denied recognition of a decision issued by a court of the Republic of Uzbekistan ๐บ๐ฟ(Case No. A40-135952/2025).
The dispute between the parties, Russian ๐ท๐บ and Uzbek ๐บ๐ฟ legal entities, has a long history that dates back to 2009.
In Case No. ะ40-120756/2009, a Russian court concluded in 2015โ2016 that the agreement between the parties was valid, whereas a court in the Republic of Uzbekistan reached the opposite conclusion in its 2025 decision.
In Case No. ะ40-135952/2025, the Arbitrazh Court of the City of Moscow states that the decision in Case No. ะ40-120756/2009 has res judicata effect and, as a result, bars the recognition of the court decision issued by the court of the Republic of Uzbekistan in 2025.
P.S. Article 245.1 of the Russian Arbitrazh Procedural Code regulates the recognition of foreign court decisions and foreign arbitral awards that do not require enforcement. It provides that an interested party may submit objections to the recognition of a foreign court decision to a Russian state court, and, if those objections are upheld, recognition of the decision in Russia will be denied.
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The Arbitrazh Court of the City of Moscow, acting pursuant to Article 245.1 of the Russian Arbitrazh Procedural Code, by its decision dated November 17, 2025, denied recognition of a decision issued by a court of the Republic of Uzbekistan ๐บ๐ฟ(Case No. A40-135952/2025).
The dispute between the parties, Russian ๐ท๐บ and Uzbek ๐บ๐ฟ legal entities, has a long history that dates back to 2009.
In Case No. ะ40-120756/2009, a Russian court concluded in 2015โ2016 that the agreement between the parties was valid, whereas a court in the Republic of Uzbekistan reached the opposite conclusion in its 2025 decision.
In Case No. ะ40-135952/2025, the Arbitrazh Court of the City of Moscow states that the decision in Case No. ะ40-120756/2009 has res judicata effect and, as a result, bars the recognition of the court decision issued by the court of the Republic of Uzbekistan in 2025.
P.S. Article 245.1 of the Russian Arbitrazh Procedural Code regulates the recognition of foreign court decisions and foreign arbitral awards that do not require enforcement. It provides that an interested party may submit objections to the recognition of a foreign court decision to a Russian state court, and, if those objections are upheld, recognition of the decision in Russia will be denied.
ProArbitration.Ru
๐๐ก๐ ๐๐ฎ๐ฉ๐ซ๐๐ฆ๐ ๐๐จ๐ฎ๐ซ๐ญ ๐จ๐ ๐๐ฎ๐ฌ๐ฌ๐ข๐ ๐๐ข๐ฌ๐ฆ๐ข๐ฌ๐ฌ๐๐ ๐ ๐๐จ๐จ๐ ๐ฅ๐ ๐๐๐ฌ๐ฌ๐๐ญ๐ข๐จ๐ง ๐๐ฉ๐ฉ๐๐๐ฅ ๐ฌ๐๐๐ค๐ข๐ง๐ ๐ซ๐๐๐จ๐ง๐ฌ๐ข๐๐๐ซ๐๐ญ๐ข๐จ๐ง ๐จ๐ ๐๐ง ๐๐ง๐ญ๐ข-๐๐ฎ๐ข๐ญ ๐๐ง๐ฃ๐ฎ๐ง๐๐ญ๐ข๐จ๐ง.
In Case No A40-24249/2025, a Russian court restrained Google from pursuing U.S. litigation against the insolvency administrator of Google LLC (Russia), and imposed a court fine of RUB 1 billion for any breach of the Anti-Suit Injunction.
On November 19, 2025, the Supreme Court of Russia declined to reconsider the case.
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In Case No A40-24249/2025, a Russian court restrained Google from pursuing U.S. litigation against the insolvency administrator of Google LLC (Russia), and imposed a court fine of RUB 1 billion for any breach of the Anti-Suit Injunction.
On November 19, 2025, the Supreme Court of Russia declined to reconsider the case.
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๐๐๐ฎ๐ญ๐ฌ๐๐ก๐ ๐๐๐ง๐ค ๐๐ซ๐ข๐ง๐ ๐ฌ ๐๐ก๐ข๐ซ๐ ๐๐ฎ๐ ๐จ๐ฏ๐จ๐ฒ ๐๐๐ฐ ๐๐ก๐๐ฅ๐ฅ๐๐ง๐ ๐
The Constitutional Court of Russia has once againโnow for the third timeโbeen asked to consider whether the Lugovoy Law (which allows courts to assert exclusive jurisdiction over commercial disputes involving sanctioned Russian parties) is compatible with the Constitution of Russia. This time, the complaint has been brought by Deutsche Bank.
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The Constitutional Court of Russia has once againโnow for the third timeโbeen asked to consider whether the Lugovoy Law (which allows courts to assert exclusive jurisdiction over commercial disputes involving sanctioned Russian parties) is compatible with the Constitution of Russia. This time, the complaint has been brought by Deutsche Bank.
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REVIEW_OF_CASE_LAW_ON_CROSS_BORDER_LITIGATION_IN_RUSSIA_BELARUS.pdf
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In Case No A56-97986/2025, the claimant, a Russian sanctioned legal entity, brought a legal action against the respondent, a Mongolian legal entity, before a Russian court. The claimant argued that the court had exclusive jurisdiction based on Art. 248.1 of the Russian Arbitrazh Procedure Code.
The court refused to entertain jurisdiction, and the appellate court confirmed this refusal.
The courts held that Mongolia is neither an "unfriendly" country nor has it enacted restrictive measures against Russian entities. Therefore, the criteria for applying Art. 248.1 were not met.
To be continued...
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Courts have recognized and enforced:
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The Russian Central Bank has brought a legal action against Euroclear Bank S.A. before a Russian court, seeking to recover more than 200 billion euros. The hearing is scheduled for January 16, 2026. Case No. A40-345157/2025.
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Courts have recognized and enforced:
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A Latvian court has requested a preliminary ruling from the Court of Justice of the European Union on the interpretation of EU law, specifically on whether EU sanctions fall within the scope of Article V(2)(b) of the New York Convention. Case C-701/25.
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A Russian court refused to enforce a domestic arbitral award because it was issued after the award debtor had entered bankruptcy. In the case at hand, the award was issued on May 20, 2025, whereas the bankruptcy proceedings were opened on July 18, 2024 (Case No ะ56-84230/2025).
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Law dated December 29, 2025, No. 8-FKZ.pdf
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