Crescent won damages of about $2.4B plus interest, now about $2.75B, after NIOC failed to deliver gas under a 2001 25-year supply contract. NIOC has resisted for a decade with challenges in Switzerland, England and the Netherlands. Crescent is now chasing NIOC assets worldwide, including a London property, frozen funds at First Islamic Investment Bank in Malaysia and assets in Greece.
LATEST DEVELOPMENT · JAN 23, 2026
On 23 January 2026, the Dutch Supreme Court rejected NIOC’s cassation appeal, confirming enforcement in the Netherlands. This followed the English Court of Appeal’s October 2025 ruling upholding enforcement orders over NIOC’s London property and a Greek enforcement decision in 2025.
BACKGROUND
Crescent Petroleum, a private UAE energy company, signed a 25-year gas sales and purchase contract with National Iranian Oil Company in 2001 under which NIOC was to supply gas from its offshore Salman field starting in 2005. NIOC never delivered the gas, and internal opposition in Tehran, including corruption allegations against the deal that were never proven in any court, led Iran to effectively abandon the contract. Crescent Petroleum assigned its rights under the contract to its subsidiary Crescent Gas Corporation and the two companies commenced UNCITRAL arbitration against NIOC in 2009, seated in London.
The tribunal issued an Award on Jurisdiction and Liability in July 2014 finding NIOC in breach, and a Partial Award on Remedies in September 2021 fixing damages at roughly 2.4 billion dollars including lost profits and other losses, a figure that has since grown with interest to around 2.75 billion dollars. NIOC has spent more than a decade resisting enforcement, first through unsuccessful jurisdictional and public-policy challenges in the English courts, and then by attempting to place assets beyond Crescent’s reach, most notably by transferring its London headquarters, NIOC House, to a related pension fund shortly after Crescent obtained permission to enforce in England.
English courts found that transfer to be a sham designed to defeat creditors and ordered it unwound, a ruling the Court of Appeal upheld in 2025 though it granted NIOC permission for a further appeal to the UK Supreme Court on novel trust law questions. In parallel, Crescent has pursued NIOC assets in the United States, where a federal court entered judgment for the full award amount, in Malaysia, where a court order allowed Crescent to reach roughly 2.3 billion dollars in NIOC-linked funds held at a bank in Labuan, and in the Netherlands and Greece, where local courts have likewise approved enforcement.
The dispute is now essentially a global asset hunt. The core arbitral award is final and unappealable, and NIOC’s remaining avenues are narrow procedural fights over specific assets, most significantly the pending UK Supreme Court appeal concerning NIOC House. Iran has publicly characterized the seizures as politically motivated, while commentators view the case as a leading example of how commercial award creditors can chase a sanctioned state enterprise’s assets across multiple jurisdictions.
TIMELINE
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JAN 23, 2026JUDGMENTDutch Supreme Court rejects NIOC’s cassation appealThe Hoge Raad refuses to revisit enforcement of the award in the Netherlands, confirming enforcement of the roughly $2.75B award against NIOC.
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DEC 2025APPEALUK Supreme Court dockets NIOC’s appeal over NIOC HouseThe UK Supreme Court registers NIOC’s appeal, case reference UKSC/2025/0190, concerning the trust and insolvency law questions in the NIOC House transfer dispute.
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OCT 2025ENFORCEMENTCrescent enforces against $2.3B in NIOC-linked funds in MalaysiaFollowing a Kuala Lumpur High Court order implementing the award, Crescent reaches roughly $2.3B held at First Islamic Investment Bank in Labuan, Malaysia, in funds linked to NIOC and its subsidiary Naftiran Intertrade Company.
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SEP 30, 2025JUDGMENTCourt of Appeal upholds unwinding of NIOC House transferThe Court of Appeal dismisses appeals by NIOC and the Retirement Fund, confirming that the transfer of NIOC House was a transaction at an undervalue, while granting permission to appeal to the Supreme Court on the underlying trust law question.
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APR 30, 2024JUDGMENTUS court confirms award and enters $2.75B judgmentThe US District Court for the District of Columbia confirms the arbitration award and enters judgment against NIOC for $2,756,123,688 including accrued interest.
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APR 15, 2024JUDGMENTHigh Court rules London property transfer was a transaction at undervalueSir Nigel Teare holds in the Commercial Court that NIOC’s transfer of NIOC House to the Retirement Fund was a transaction at an undervalue made to put the property beyond Crescent’s reach, contrary to section 423 of the Insolvency Act 1986.
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JUL 13, 2023JUDGMENTCourt of Appeal dismisses NIOC’s jurisdictional challengeThe Court of Appeal of England and Wales dismisses NIOC’s appeal against the summary dismissal of its section 67 challenge to the tribunal’s jurisdiction over the award.
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AUG 2022OTHERNIOC transfers London headquarters days after enforcement permission grantedDays after Crescent Gas obtained permission to enforce the award in England, NIOC transferred NIOC House, its London headquarters, to the Retirement, Savings and Welfare Fund of Oil Industry Workers, a transfer later found to be at an undervalue and designed to defeat creditors.
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MAY 16, 2022FILINGCrescent petitions US court to confirm the awardCrescent Petroleum and Crescent Gas Corporation file a petition to confirm the foreign arbitration award in the US District Court for the District of Columbia.
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SEP 27, 2021AWARDTribunal issues Partial Award on Remedies, ordering ~$2.4B in damagesThe tribunal awards Crescent roughly 1.33 billion dollars for lost profits and about 1.08 billion dollars for other losses, totaling over 2 billion dollars, plus interest, bringing the headline figure to about 2.4 billion dollars.
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MAR 4, 2016JUDGMENTEnglish High Court rejects NIOC’s challenge to liability awardThe English High Court dismisses NIOC’s application under sections 67 and 68 of the Arbitration Act 1996 to set aside the Award on Jurisdiction and Liability.
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JUL 31, 2014AWARDTribunal issues Award on Jurisdiction and LiabilityThe tribunal finds that the GSPC was valid and binding and that NIOC breached the contract by failing to deliver gas.
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2009FILINGCrescent commences UNCITRAL arbitration against NIOCAfter NIOC failed to deliver gas under the 2001 contract, Crescent Petroleum and Crescent Gas Corporation commenced ad hoc UNCITRAL arbitration, registered as PCA Case No. 2009-20, seated in London.
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APR 25, 2001OTHERGSPC gas supply contract signedNational Iranian Oil Company and Crescent Petroleum Company International Ltd sign a 25-year Gas Sales and Purchase Contract for gas from Iran’s offshore Salman field, with side letters and a later amendment.