🇷🇺 𝐑𝐮𝐬𝐬𝐢𝐚𝐧 𝐂𝐨𝐮𝐫𝐭 𝐂𝐨𝐧𝐟𝐢𝐫𝐦𝐬 𝐭𝐡𝐚𝐭 "𝐔𝐧𝐟𝐫𝐢𝐞𝐧𝐝𝐥𝐲" 𝐒𝐭𝐚𝐭𝐮𝐬 𝐈𝐬 𝐍𝐨𝐭 𝐚 𝐁𝐚𝐫 𝐭𝐨 𝐄𝐧𝐟𝐨𝐫𝐜𝐞𝐦𝐞𝐧𝐭.

In Case No. A82-19719/2025, the award debtor objected to the enforcement of an arbitral award rendered in a Moscow-seated arbitration, arguing that the award creditor was domiciled in Bulgaria 🇧🇬 — a country considered "unfriendly" to Russia — and therefore, enforcement should be denied under Russian counter-sanctions measures.

The court of first instance by decision dated October 10, 2025 rejected this argument, holding that the mere fact that a party to the arbitration is domiciled in a country deemed "unfriendly" to Russia does not, by itself, preclude the enforcement of the arbitral award.

It is worth noting that, earlier in this case, the court had refused enforcement by a decision dated April 2, 2025, referring specifically to Russian counter-sanctions measures. However, the cassation court overturned that decision and remanded the case for reconsideration.

P.S. The same approach — that domiciliation in a country deemed “unfriendly” to Russia does not, by itself, preclude the enforcement of an arbitral award — was taken in relation to an award debtor domiciled in Switzerland 🇨🇭 (see Case No. А43-27728/2024).

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