POLITICAL-LEGAL TRANSFORMATION OF THE RECOGNITION AND ENFORCEMENT OF FOREIGN COURT AND ARBITRAL DECISIONS IN THE RUSSIAN FEDERATION (2019–2025)
Published: January 31, 2026
Author: Khrabrykh S. A.

This report, prepared by Observatoire ARGA, is devoted to a systematic analysis of the practice of recognition and enforcement of foreign court and arbitral decisions in the Russian Federation during the period 2019–2025. The study relies on quantitative court statistics, institutional analysis, and a comparison of enforcement dynamics before and after 2022.

The report demonstrates that changes in Russian practice are structural rather than fragmentary. The mechanism for recognizing foreign decisions is gradually transforming from a universal legal tool into a selective politico-jurisdictional filter, depending on the origin of the decision, the status of the jurisdiction, and the institutional affiliation of the arbitration. Formally high recognition rates are largely ensured by decisions from neutral and post-Soviet jurisdictions, while decisions from courts and arbitrations of “unfriendly” states increasingly face refusals.

Particular attention is paid to the role of the cassation instance and the Supreme Court of the Russian Federation, which generate institutional signals influencing the predictability of law enforcement. The report also analyzes the sharp decline in international arbitration cases and the loss of its neutral status in the Russian jurisdiction.

In its conclusion, the study links the identified trends to sanctions pressure and examines them in the context of Russia’s claim against Euroclear as an element of asymmetric legal response. The ARGA report records a profound transformation of the architecture of international commercial disputes involving Russia and its consequences for legal certainty, the investment climate, and the global financial-legal system.

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