AND ENFORCEMENT OF FOREIGN
JUDICIAL AND ARBITRAL AWARDS
IN THE RUSSIAN FEDERATION (2019–2025)
This report was prepared by Observatoire ARGA and provides a comprehensive analysis of the practice of recognition and enforcement of foreign judicial and arbitral decisions in the Russian Federation during the period 2019–2025. The study is based on quantitative court statistics, institutional analysis, and a comparative assessment of enforcement dynamics before and after 2022.
The report demonstrates that the changes observed in Russian practice are not fragmentary but systemic in nature. The mechanism for recognizing foreign decisions is gradually transforming from a universal legal instrument into a selective political and jurisdictional filter, dependent on the origin of the decision, the status of the jurisdiction, and the institutional affiliation of the arbitral body. Formally high recognition rates are largely sustained by decisions originating from neutral and post-Soviet jurisdictions, while judgments and awards from courts and arbitral institutions of so-called “unfriendly” states increasingly face refusal.
Special attention is given to the role of the cassation instance and the Supreme Court of the Russian Federation, whose institutional signals significantly affect the predictability of legal outcomes. The report also analyses the sharp decline in the number of international arbitration cases and the gradual loss of arbitration’s neutral status within the Russian jurisdiction.
In its concluding section, the study links these trends to sanctions pressure and examines them in the context of the Russian Federation’s claim against Euroclear as an element of an asymmetric legal response. The ARGA report identifies a profound transformation in the architecture of international commercial disputes involving Russia and highlights its consequences for legal certainty, the investment climate, and the global financial and legal system.
Citation Rules
-
Mandatory source attribution.
When using materials from ARGA Observatory, you must indicate the full name — ARGA Observatory — and the exact title of the report or article. -
Indication of date and version.
For analytical reports, it is required to specify the year of publication and, if applicable, the document’s version number. -
Link to the original.
Digital materials must include an active link to the official ARGA Observatory website or the specific report page. -
Preservation of context.
Quotations must not be shortened or altered in a way that distorts the meaning of the original text. -
Separate note for adaptations.
If the text is shortened, translated, or adapted, the following statement must be added: “adapted from an ARGA Observatory report.” -
No commercial use without permission.
The use of ARGA Observatory materials for commercial purposes is allowed only with written permission from the organization. -
Attribution of authors.
When citing reports with listed authors, they must be indicated exactly as presented on the title page. -
Accuracy of data.
Charts, tables, and statistics must be reproduced without changes to numbers or wording.