🇷🇺🇺🇸 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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🇷🇺 𝐑𝐞𝐜𝐨𝐠𝐧𝐢𝐭𝐢𝐨𝐧 𝐚𝐧𝐝 𝐄𝐧𝐟𝐨𝐫𝐜𝐞𝐦𝐞𝐧𝐭 𝐨𝐟 𝐅𝐨𝐫𝐞𝐢𝐠𝐧 𝐂𝐨𝐮𝐫𝐭 𝐃𝐞𝐜𝐢𝐬𝐢𝐨𝐧𝐬: 𝐅𝐞𝐛𝐫𝐮𝐚𝐫𝐲 𝟏𝟑–𝟐𝟎, 𝟐𝟎𝟐𝟔

🇺🇿 In Case No. А45-2768/2024, a cassation court confirmed the lower court decision recognizing and enforcing a decision issued by a court of the Republic of Uzbekistan.

🇺🇿 In Case No. А76-48510/2025, a Russian court recognized and enforced a decision issued by a court of the Republic of Uzbekistan.

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🇷🇺🇧🇪 𝐑𝐞𝐜𝐨𝐠𝐧𝐢𝐭𝐢𝐨𝐧 𝐨𝐟 𝐚 𝐁𝐞𝐥𝐠𝐢𝐚𝐧 𝐂𝐨𝐮𝐫𝐭 𝐃𝐞𝐜𝐢𝐬𝐢𝐨𝐧 𝐢𝐧 𝐑𝐮𝐬𝐬𝐢𝐚: 𝐑𝐞𝐜𝐢𝐩𝐫𝐨𝐜𝐢𝐭𝐲 𝐚𝐧𝐝 𝐈𝐧𝐭𝐞𝐫𝐧𝐚𝐭𝐢𝐨𝐧𝐚𝐥 𝐂𝐨𝐦𝐢𝐭𝐲 𝐚𝐬 𝐆𝐫𝐨𝐮𝐧𝐝𝐬

In Case No. А56-23597/2023 concerning the insolvency (bankruptcy) of a Russian citizen, an appellate court confirmed a lower court decision dated August 5, 2025, recognizing a court decision issued by a court in Antwerp, the Kingdom of Belgium.

It is worth noting that the lower court decision dated August 5, 2025, was based on both the principle of international comity and the principle of reciprocity, since the Russian Federation and the Kingdom of Belgium have no international treaty on the recognition and enforcement of court decisions. The court stated in its decision dated August 5, 2025:

"the principle of reciprocity presupposes mutual respect by the courts of different states for the outcomes of each other’s activities. Accordingly, it may be concluded that even in the absence of an international treaty between the Russian Federation and the state whose court judgment is sought to be recognized and enforced before a Russian court, such a foreign judgment is subject to enforcement on the basis of the principles of reciprocity and international comity."

🔗 The appeal court decision dated 14 February 2026 can be found at the following link, and the first-instance court decision dated 5 August 2025 can be found at the following link. All decisions are in Russian.

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In Case No A56-114163/2025, a Russian court refused to issue an order for the disclosure of customs documents in support of a Russian-seated arbitration because these documents contain legally protected information.

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Whether unilateral sanctions fall within the ‘public policy’ exception under Article V(2)(b) of the New York Convention?

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In Case C-802/24, the Advocate General delivered his Opinion on 26 February 2026. He considers that Article 11(1) of Council Regulation (EU) No 833/2014 of 31 July 2014 does not preclude recourse to arbitration in respect of a claim that cannot be satisfied within the meaning of that provision. However, satisfaction must in fact be unobtainable, and any arbitral award must remain subject to judicial review in order to ensure compliance with EU public policy.

The full Opinion is available at the following link - https://infocuria.curia.europa.eu/tabs/document/C/2024/C-0802-24-00000000RP-01-P-01/CONCL/316861-EN-1-html

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🇷🇺 𝐑𝐮𝐬𝐬𝐢𝐚𝐧 𝐄𝐧𝐟𝐨𝐫𝐜𝐞𝐦𝐞𝐧𝐭 𝐔𝐩𝐝𝐚𝐭𝐞: 𝐅𝐞𝐛𝐫𝐮𝐚𝐫𝐲 𝟐𝟎–𝟐𝟕, 𝟐𝟎𝟐𝟔

🇰🇿 A court refused to recognize and enforce in Russia a decision issued by a court of the Republic of Kazakhstan — the debtor was not duly served with notice of the proceedings before the Kazakh court (decision of 24 February 2026, Case No. А19-1350/2026).

🇦🇿 A cassation court confirmed a lower court decision on the recognition and enforcement of a decision issued by a court of the Republic of Azerbaijan (decision of 25 February 2026, Case No. А15-4529/2025).

🇰🇿 A court recognized and enforced an SCC award issued against a Kazakh bank (decision of 20 February 2026, Case No. А40-118932/2025).

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🇷🇺 𝗣𝗿𝗼𝘀𝗲𝗰𝘂𝘁𝗼𝗿 𝗚𝗲𝗻𝗲𝗿𝗮𝗹 𝗦𝗲𝗲𝗸𝘀 𝗟𝗶𝗳𝗲𝘁𝗶𝗺𝗲 𝗕𝗮𝗻 𝗼𝗻 𝗔𝗿𝗯𝗶𝘁𝗿𝗮𝘁𝗼𝗿 𝗖𝗵𝗮𝗿𝗹𝗲𝘀 𝗣𝗼𝗻𝗰𝗲𝘁

The Prosecutor General of the Russian Federation has brought a legal action before a Russian court seeking the lifelong disqualification of Mr. Charles Poncet as an arbitrator and a ban preventing Mr. Charles Poncet from acting as an arbitrator in all arbitral institutions that directly or indirectly consider cases against the Russian Federation.

The case (No А40-57198/26-19-530) is scheduled to be heard on April 16, 2026.

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🇷🇺 𝗥𝘂𝘀𝘀𝗶𝗮𝗻 𝗘𝗻𝗳𝗼𝗿𝗰𝗲𝗺𝗲𝗻𝘁 𝗨𝗽𝗱𝗮𝘁𝗲: 𝗠𝗮𝗿𝗰𝗵 𝟮–𝟭𝟯, 𝟮𝟬𝟮𝟲

🇰🇿 Russian courts recognized and enforced two decisions issued by courts of the Republic of Kazakhstan (Case No. A46-2266/2026, decision dated 11 March 2026; Case No. A56-112332/2025, decision dated 12 March 2026).

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🇷🇺🇰🇿 From March 13 to 27, 2026, Russian courts recognized and enforced decisions issued by courts of the Republic of Kazakhstan (Cases Nos. A53-36344/2025, A40-317586/2025, and A72-14559/2025).

ProArbitration.Ru ✈

🇷🇺🇰🇿🇧🇾 𝗥𝘂𝘀𝘀𝗶𝗮𝗻 𝗘𝗻𝗳𝗼𝗿𝗰𝗲𝗺𝗲𝗻𝘁 𝗨𝗽𝗱𝗮𝘁𝗲. From 27 March to 10 April 2026, Russian courts recognized and enforced decisions issued by courts in the Republic of Kazakhstan (Case Nos. A27-29886/2025, A76-161/2026, and A60-74989/2025) and the Republic of Belarus (Case No. A40-54946/2026).

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The Poncet case, where Russia’s state prosecutor is seeking to impose a lifetime ban on Charles Poncet as an arbitrator, has been postponed until November 2, 2026.

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𝗥𝘂𝘀𝘀𝗶𝗮𝗻 𝗖𝗮𝘀𝘀𝗮𝘁𝗶𝗼𝗻 𝗖𝗼𝘂𝗿𝘁 𝗢𝘃𝗲𝗿𝘁𝘂𝗿𝗻𝘀 𝗜𝗻𝘁𝗲𝗿𝗶𝗺 𝗠𝗲𝗮𝘀𝘂𝗿𝗲𝘀 𝗶𝗻 𝗟𝗖𝗜𝗔 𝗗𝗶𝘀𝗽𝘂𝘁𝗲; 𝗖𝗮𝘀𝗲 𝗥𝗲𝗺𝗮𝗻𝗱𝗲𝗱.

On August 1, 2025, a Russian court of general jurisdiction granted interim measures freezing assets in support of an LCIA arbitration. By decision dated October 20, 2025, the court of appeal upheld the interim measures. However, by decision dated February 17, 2026, a cassation court overturned the appellate decision and remanded the matter to the court of appeal for reconsideration.

🔗 Follow the link to access the cassation court’s decision (in Russian) - https://2kas.sudrf.ru/modules.php?name=sud_delo&srv_num=1&name_op=doc&number=18168537&delo_id=2800001&new=2800001&text_number=1

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𝑭𝒓𝒐𝒎 𝑰𝑪𝑪 𝑳𝒐𝒔𝒔 𝒕𝒐 𝑫𝒐𝒎𝒆𝒔𝒕𝒊𝒄 𝑾𝒊𝒏: $9𝑴 𝑹𝒆𝒄𝒐𝒗𝒆𝒓𝒆𝒅 𝒊𝒏 𝑹𝒖𝒔𝒔𝒊𝒂

A Russian entity lost an ICC arbitration, as EU sanctions prevented the repayment of an advance payment. However, it subsequently succeeded in resisting recognition of the ICC award in Russia (see case No. А42-5661/2025) and then initiated proceedings before a Russian court. The court ultimately granted the claim, ordering German and Latvian companies to repay nearly $9 million in advance payments to the Russian entity (see case No. А42-2551/2025).

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𝐑𝐮𝐬𝐬𝐢𝐚𝐧 𝐀𝐩𝐩𝐞𝐚𝐥 𝐂𝐨𝐮𝐫𝐭 𝐑𝐞𝐣𝐞𝐜𝐭𝐬 𝐈𝐧𝐭𝐞𝐫𝐢𝐦 𝐌𝐞𝐚𝐬𝐮𝐫𝐞𝐬 𝐢𝐧 𝐒𝐮𝐩𝐩𝐨𝐫𝐭 𝐨𝐟 𝐋𝐂𝐈𝐀 𝐀𝐫𝐛𝐢𝐭𝐫𝐚𝐭𝐢𝐨𝐧

On August 1, 2025, a Russian court of general jurisdiction granted interim measures freezing assets in support of an LCIA arbitration. By decision dated October 20, 2025, a court of appeal upheld those interim measures. However, by decision dated February 17, 2026, a cassation court overturned the appellate decision and remanded the matter to the court of appeal for reconsideration.

Upon reconsideration, on April 29, 2026, the court of appeal overturned the interim measures granted in support of the LCIA arbitration. The court held, on the one hand, that the motion for interim measures had not been supported by sufficient evidence demonstrating the necessity and proportionality of the requested relief. On the other hand, in refusing to grant interim measures, the court noted that the seat of arbitration is located in an "unfriendly" country.

🔗 Here is a link to the appellate court decision.

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