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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Ministry of Justiceโs registry.pdf
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On 26 December 2025, the Dubai International Arbitration Centre (DIAC) was registered as a Permanent Arbitral Institution by the Russian Ministry of Justice, enabling it to administer international commercial arbitrations seated in Russia and certain corporate disputes.
The same status has also been granted to HKIAC, VIAC, SIAC, ICC, and CRCICA.
The Ministry of Justiceโs registry, in Russian, is attached.
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The same status has also been granted to HKIAC, VIAC, SIAC, ICC, and CRCICA.
The Ministry of Justiceโs registry, in Russian, is attached.
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In connection with a bankruptcy/insolvency proceeding involving a Russian citizen (the โDebtorโ), a Russian state court issued a letter rogatory request (order dated February 4, 2025) seeking information from a U.S. bank regarding the Debtorโs account history, assets, loans, and other financial information.
Pursuant to this request, the U.S. Government filed an application dated September 3, 2025, requesting that a U.S. court grant judicial assistance.
On September 25, 2025, the U.S. court granted the requested judicial assistance.
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Order - 24-12-2025.pdf
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On 5 December 2025, a Russian court handed down a decision ordering an Italian entity and its Russian subsidiary to pay RUB 171 billion to the Russian entity (see Case No. ะ40-231304/2025). Despite the fact that the court decision has not attained finality, as all parties have filed appeals, the Russian entity commenced proceedings under Section 13 of the Code of Civil Procedure, 1908 (India), seeking interim relief.
On 24 December 2025, the High Court of Bombay did not pass any orders. Subsequently, by an order dated 12 January 2026, as indicated by published reports, the Court granted interim measures requiring the Italian company to maintain the status quo in relation to its Indian assets, which are understood to be valued at over EUR 300 million.
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KSRFDecision885005.pdf
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The Lugovoy Law has survived a third attempt at constitutional review. The Russian Constitutional Court refused to consider an application brought by Deutsche Bank. The applicant was of the opinion that Art. 248.2 of the Russian Arbitrazh Code, granting Russian courts the power to restrain foreign parties from commencing and/or continuing foreign litigation proceedings and/or arbitration outside of Russia, is unconstitutional. By its Ruling dated December 25, 2025 (published today), the Russian Constitutional Court refused to consider the application.
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