🇷🇺🇺🇸 𝐑𝐮𝐬𝐬𝐢𝐚𝐧 𝐂𝐨𝐮𝐫𝐭 𝐑𝐞𝐟𝐮𝐬𝐞𝐬 𝐭𝐨 𝐑𝐞𝐜𝐨𝐠𝐧𝐢𝐬𝐞 𝐚 𝐔𝐒 𝐁𝐚𝐧𝐤𝐫𝐮𝐩𝐭𝐜𝐲 𝐂𝐨𝐮𝐫𝐭 𝐃𝐞𝐜𝐢𝐬𝐢𝐨𝐧: 𝐍𝐨 𝐑𝐞𝐜𝐢𝐩𝐫𝐨𝐜𝐢𝐭𝐲 𝐚𝐧𝐝 𝐍𝐨 𝐑𝐞𝐜𝐨𝐠𝐧𝐢𝐭𝐢𝐨𝐧 𝐨𝐟 𝐈𝐧𝐭𝐞𝐫𝐢𝐦 𝐃𝐞𝐜𝐢𝐬𝐢𝐨𝐧𝐬

In Case No. A40-35982/2026, the bankruptcy trustee sought recognition and enforcement in Russia of a decision rendered by the United States Bankruptcy Court for the Central District of California on 17 November 2025 in the bankruptcy proceedings concerning individual E. In particular, the trustee requested the Russian court to:

- recognise the decision in Russia;
- give effect in Russia to the decision’s prohibition on asserting claims against the debtor; and
- recognise the trustee’s authority to act on behalf of the debtor in respect of the debtor’s assets located in Russia.

The Court’s position

1. Russia and the United States have no treaty providing for the reciprocal recognition of judgments rendered by their respective national courts, nor are they parties to a common convention governing such recognition. The Court held that the absence of reciprocity was itself contrary to Russian public policy.

2. Interim judicial acts of foreign courts — a category into which the Court placed the decision of 17 November 2025 — are not eligible for recognition and enforcement in Russia.

In sum: By a decision dated 18 September 2026, a Russian court dismissed the application for recognition and enforcement of the US court decision.

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