𝗥𝘂𝘀𝘀𝗶𝗮𝗻 𝗖𝗼𝘂𝗿𝘁 𝗘𝗻𝗳𝗼𝗿𝗰𝗲𝘀 𝗜𝗖𝗖 𝗔𝘄𝗮𝗿𝗱, 𝗥𝗲𝗷𝗲𝗰𝘁𝘀 𝗣𝘂𝗯𝗹𝗶𝗰 𝗣𝗼𝗹𝗶𝗰𝘆 𝗮𝗻𝗱 𝗦𝗮𝗻𝗰𝘁𝗶𝗼𝗻𝘀 𝗢𝗯𝗷𝗲𝗰𝘁𝗶𝗼𝗻𝘀. In Case No. A60-26002/2026, a decision dated 24 July 2026, a Russian court issued a writ of execution for an ICC arbitral award rendered in an arbitration seated in Moscow and held:

1. An assignment of a claim under a foreign trade supply contract from a Dutch assignor to a Russian assignee does not, in itself, violate Russian public policy and does not fall under the Russian counter-sanctions measures.

2. Refusing enforcement of an award on public policy grounds requires two cumulative elements: a breach of the fundamental principles of the Russian legal system, and the occurrence of harmful consequences — damage to sovereignty, to the interests of large social groups, or to constitutional rights. The respondent failed to prove any such consequences.

3. The argument that the tribunal was improperly constituted (a sole arbitrator instead of the three provided for in the contract) was rejected on estoppel grounds: having failed to object to the tribunal's composition at the ICC case management conference, the respondent forfeited the right to raise this ground at the enforcement stage.

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