Political and Legal Transformation of the Recognition and Enforcement of Foreign Judicial and Arbitral Decisions in the Russian Federation (2019–2025)
This report was prepared by ARGA Observatory and is devoted to a systematic 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 judicial statistics, institutional analysis, and a comparison of enforcement dynamics before and after 2022.
The report demonstrates that changes in Russian practice are not fragmented but structural in nature. The mechanism for recognizing foreign decisions is gradually transforming from a universal legal instrument into a selective politico-jurisdictional filter, dependent on the origin of the decision, the status of the issuing jurisdiction, and the institutional affiliation of the arbitral body. Formally high recognition rates are achieved primarily through decisions originating from neutral and post-Soviet jurisdictions, while decisions of courts and arbitral tribunals from “unfriendly” states increasingly face refusals.
Special attention is given 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 the number of international arbitration cases and the loss of arbitration’s neutral status within the Russian jurisdiction.
In its concluding section, the study links the identified 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 records a profound transformation of the architecture of international commercial disputes involving Russia and assesses its consequences for legal certainty, the investment climate, and the global financial and legal system.
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