🇷🇺🇧🇾🇺🇿 The RAA Review of case law on cross-border litigation in Russia, Belarus, and Uzbekistan for the first half of 2025 has been published.

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🇷🇺Court Updates on Enforcement in Russia (November 24 – December 7)

🇧🇾A court has recognized and enforced an arbitral award rendered under the auspices of the Belarusian Chamber of Commerce and Industry (Case No. A68-13217/2025). #Belarus

🇺🇿A court has refused to recognize and enforce a court decision rendered by a court of the Republic of Uzbekistan (Case No. A07-31109/2025). The court found that the Russian company, a party against whom the court decision was made, was not properly informed about the court proceedings before the court of the Republic of Uzbekistan. #Uzbekistan

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🇷🇺🇲🇳 𝗔 𝗹𝗲𝗴𝗮𝗹 𝗮𝗰𝘁𝗶𝗼𝗻 𝗮𝗴𝗮𝗶𝗻𝘀𝘁 𝗮 𝗠𝗼𝗻𝗴𝗼𝗹𝗶𝗮𝗻 𝗹𝗲𝗴𝗮𝗹 𝗲𝗻𝘁𝗶𝘁𝘆 𝗯𝗮𝘀𝗲𝗱 𝗼𝗻 𝘁𝗵𝗲 𝗟𝘂𝗴𝗼𝘃𝗼𝘆 𝗔𝗰𝘁 𝗵𝗮𝘀 𝗳𝗮𝗶𝗹𝗲𝗱 𝘀𝗼 𝗳𝗮𝗿.

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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🇷🇺 𝗖𝗼𝘂𝗿𝘁 𝗨𝗽𝗱𝗮𝘁𝗲𝘀 𝗼𝗻 𝗘𝗻𝗳𝗼𝗿𝗰𝗲𝗺𝗲𝗻𝘁 𝗶𝗻 𝗥𝘂𝘀𝘀𝗶𝗮 (𝗗𝗲𝗰𝗲𝗺𝗯𝗲𝗿 𝟳–𝟭𝟮, 𝟮𝟬𝟮𝟱)

Courts have recognized and enforced:

🇧🇾 an arbitral award rendered under the auspices of the Belarusian Chamber of Commerce and Industry (Case No. А40-280097/2025) #Belarus; and

🇰🇿 a decision issued by a court of the Republic of Kazakhstan (Case No. А76-36796/2025). #Kazakhstan

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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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🇷🇺 𝗖𝗼𝘂𝗿𝘁 𝗨𝗽𝗱𝗮𝘁𝗲𝘀 𝗼𝗻 𝗘𝗻𝗳𝗼𝗿𝗰𝗲𝗺𝗲𝗻𝘁 𝗶𝗻 𝗥𝘂𝘀𝘀𝗶𝗮 (𝗗𝗲𝗰𝗲𝗺𝗯𝗲𝗿 𝟭𝟱–𝟭𝟵, 𝟮𝟬𝟮𝟱)

Courts have recognized and enforced:

🇺🇿 a Tashkent International Arbitration Centre (TIAC) award (Case No. А40-229097/2025). This is the first time such an award has been recognized in Russia; #Uzbekistan

🇧🇾 an arbitral award rendered under the auspices of the Belarusian Universal Commodity Exchange (Case No. А40-280097/2025). #Belarus

🇰🇿 A cassation court confirmed a lower court decision on the recognition and enforcement of a decision issued by a court of the Republic of Kazakhstan (Case No. А40-154875/2025). #Kazakhstan.

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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 А56-84230/2025).

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🇷🇺 𝗖𝗼𝘂𝗿𝘁 𝗨𝗽𝗱𝗮𝘁𝗲𝘀 𝗼𝗻 𝗘𝗻𝗳𝗼𝗿𝗰𝗲𝗺𝗲𝗻𝘁 𝗶𝗻 𝗥𝘂𝘀𝘀𝗶𝗮 (𝗗𝗲𝗰𝗲𝗺𝗯𝗲𝗿 𝟮𝟮-𝟮𝟲, 𝟮𝟬𝟮𝟱)

🇰🇿A Russian court has recognized and enforced a decision issued by a court of the Republic of Kazakhstan (Case No. A40-248600/2025). #Kazakhstan

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🇷🇺 According to a law published today, Russia does not recognise judgements issued by international criminal courts if the jurisdiction of such a court is not based on an international treaty to which Russia is a party, nor on Chapter VII of the United Nations Charter 🇺🇳(see Federal Constitutional Law dated December 29, 2025, No. 8-FKZ).

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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 Justice’s registry, in Russian, is attached.

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🇷🇺🇺🇸 𝗨.𝗦. 𝗖𝗼𝘂𝗿𝘁 𝗚𝗿𝗮𝗻𝘁𝘀 𝗝𝘂𝗱𝗶𝗰𝗶𝗮𝗹 𝗔𝘀𝘀𝗶𝘀𝘁𝗮𝗻𝗰𝗲 𝘁𝗼 𝗥𝘂𝘀𝘀𝗶𝗮𝗻 𝗖𝗼𝘂𝗿𝘁

In connection with a bankruptcy/insolvency proceeding involving a Russian citizen (the “Debtor”), a Russian state court issued a letter rogatory request (order dated February 4, 2025) seeking information from a U.S. bank regarding the Debtor’s 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.

🔗

🇷🇺 The Russian court case is available at the following link.

🇺🇸 The U.S. court case is available at the following link.

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🇷🇺🇮🇳 𝐈𝐧𝐝𝐢𝐚𝐧 𝐜𝐨𝐮𝐫𝐭 𝐠𝐫𝐚𝐧𝐭𝐬 𝐄𝐔𝐑 𝟑𝟎𝟎 𝐦𝐢𝐥𝐥𝐢𝐨𝐧 𝐢𝐧𝐭𝐞𝐫𝐢𝐦 𝐫𝐞𝐥𝐢𝐞𝐟 𝐢𝐧 𝐑𝐮𝐬𝐬𝐢𝐚-𝐥𝐢𝐧𝐤𝐞𝐝 𝐝𝐢𝐬𝐩𝐮𝐭𝐞 𝐛𝐫𝐨𝐮𝐠𝐡𝐭 𝐛𝐲 𝐚 𝐑𝐮𝐬𝐬𝐢𝐚𝐧 𝐞𝐧𝐭𝐢𝐭𝐲

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. А40-231304/2025). 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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🇷🇺 𝐑𝐮𝐬𝐬𝐢𝐚 𝐄𝐧𝐟𝐨𝐫𝐜𝐞𝐦𝐞𝐧𝐭 𝐔𝐩𝐝𝐚𝐭𝐞: 𝐉𝐚𝐧𝐮𝐚𝐫𝐲 𝟏𝟐–𝟑𝟎, 𝟐𝟎𝟐𝟔

🇰🇿 In Case No. А76-38020/2025, a Russian court recognized and enforced in Russia a decision issued by a court of the Republic of Kazakhstan.

🇺🇿 In Case No. А32-46804/2025, a Russian court refused to recognize and enforce in Russia a decision issued by a court of the Republic of Uzbekistan because the debtor was not duly served with notice of the proceedings before the foreign court.

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🇷🇺 𝐓𝐡𝐞 𝐋𝐮𝐠𝐨𝐯𝐨𝐲 𝐋𝐚𝐰 𝐒𝐮𝐫𝐯𝐢𝐯𝐞𝐬 𝐚 𝐓𝐡𝐢𝐫𝐝 𝐂𝐨𝐧𝐬𝐭𝐢𝐭𝐮𝐭𝐢𝐨𝐧𝐚𝐥 𝐂𝐡𝐚𝐥𝐥𝐞𝐧𝐠𝐞

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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🇷🇺 𝐑𝐞𝐜𝐨𝐠𝐧𝐢𝐭𝐢𝐨𝐧 𝐚𝐧𝐝 𝐄𝐧𝐟𝐨𝐫𝐜𝐞𝐦𝐞𝐧𝐭 𝐨𝐟 𝐅𝐨𝐫𝐞𝐢𝐠𝐧 𝐂𝐨𝐮𝐫𝐭 𝐃𝐞𝐜𝐢𝐬𝐢𝐨𝐧𝐬: 𝐅𝐞𝐛𝐫𝐮𝐚𝐫𝐲 𝟐–𝟏𝟑, 𝟐𝟎𝟐𝟔

🇰🇿 In Case No. А76-498/2026, a Russian court recognized and enforced a decision issued by a court of the Republic of Kazakhstan.

🇺🇿 In Case No. A07-31108/2025, a Russian court refused to recognize and enforce in Russia a decision issued by a court of the Republic of Uzbekistan because the debtor had not been duly served with notice of the proceedings before the foreign court.

⚠️ P.S. Case No. A07-31108/2025 is the second case this year in which recognition and enforcement of decisions issued by courts of the Republic of Uzbekistan 🇺🇿have been refused because debtors were not duly served with notice of the proceedings before foreign courts. The first case was No. A32-46804/2025; see here.

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🇨🇾🇷🇺 𝐂𝐲𝐩𝐫𝐮𝐬 𝐂𝐨𝐮𝐫𝐭 𝐈𝐧𝐯𝐨𝐤𝐞𝐬 𝐏𝐮𝐛𝐥𝐢𝐜 𝐏𝐨𝐥𝐢𝐜𝐲 𝐭𝐨 𝐃𝐞𝐧𝐲 𝐄𝐧𝐟𝐨𝐫𝐜𝐞𝐦𝐞𝐧𝐭 𝐨𝐟 𝐋𝐂𝐈𝐀 𝐀𝐰𝐚𝐫𝐝 𝐀𝐦𝐢𝐝 𝐑𝐮𝐬𝐬𝐢𝐚𝐧 𝐁𝐚𝐧𝐤𝐫𝐮𝐩𝐭𝐜𝐲.

The case concerns an attempt to recognise and enforce a USD 82 million LCIA award in Cyprus against the Ananiev brothers, former Russian bankers. Since 2019 and 2022 respectively, Alexey and Dmitry have been subject to bankruptcy proceedings in Russia.

A Cyprus court refused recognition and enforcement of the LCIA award because such recognition would be in conflict with Russian bankruptcy proceedings. The reasons of the Cyprus court are as follows (a machine translation from the Greek language into the English language):

"It is a fact that any issuance of the requested decrees will result in the bypassing of the priority of the creditors of the Respondent. I consider that the interests of the body of creditors prevail over the interests of the Applicants who, with the present application, are attempting to collect their receivables to the detriment of the remaining creditors."

"The disregard of the interests of creditors for the benefit of the Applicants is something that is clearly contrary to Cypriot public order."

📃 The Cyprus decision is available at the following link.

P.S. The post in Russian is available here.

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🇷🇺🇰🇿 𝐑𝐮𝐬𝐬𝐢𝐚𝐧 𝐂𝐨𝐮𝐫𝐭 𝐑𝐞𝐟𝐮𝐬𝐞𝐬 𝐑𝐞𝐜𝐨𝐠𝐧𝐢𝐭𝐢𝐨𝐧 𝐚𝐧𝐝 𝐄𝐧𝐟𝐨𝐫𝐜𝐞𝐦𝐞𝐧𝐭 𝐨𝐟 𝐊𝐚𝐳𝐚𝐤𝐡 𝐂𝐨𝐮𝐫𝐭-𝐎𝐫𝐝𝐞𝐫𝐞𝐝 𝐈𝐧𝐭𝐞𝐫𝐢𝐦 𝐌𝐞𝐚𝐬𝐮𝐫𝐞𝐬 𝐢𝐧 𝐀𝐢𝐝 𝐨𝐟 𝐀𝐫𝐛𝐢𝐭𝐫𝐚𝐭𝐢𝐨𝐧

A court in Kazakhstan granted interim measures in support of an arbitration seated in Kazakhstan. The claimant applied to a Russian court for recognition and enforcement of that order. The first-instance court granted the application. The cassation court overturned the first-instance court’s decision and denied the claimant’s application, holding that interim measures are not enforceable in Russia (decision of 17 February 2026, Case No. A14-12983/2024).

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