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84

2 places down No. 82 last week

Commercial LitigationEnforcementCommercial arbitration & enforcementFinancial services

DubaiAlso in the Dubai collection.

Mozambique v. Privinvest

The Republic of Mozambique v. Privinvest Shipbuilding SAL (Holding) and Others (“Tuna Bonds” / Hidden Debts)

Mozambique pursues Privinvest, the Safa estate, and Safa’s widow over tuna bonds bribery

Rank, last 10 weeks Best No. 82 · lowest No. 99
No. 1102030405060708090100 9799998284
At stake
~$2.3BStakes rated 34 of 100
Score
43.6Out of 100
Latest event
Oct 21, 20262 weeks ago
Next step
Not scheduledNothing dated on the record yet
Commenced
20197 yr 4 mo ago
Court
English Court of Appeal[2024] EWHC 1957

Stage

Enforcement. A final decision or settlement is being enforced, paid out or collected. How cases are placed

  1. Filed
  2. Pre-trial
  3. Trial
  4. Decision
  5. Appeal
  6. EnforcementNow

The Republic of Mozambique sued Privinvest and its late owner Iskandar Safa in London, alleging bribery behind the $2B “tuna bonds” hidden-debt scandal. The Commercial Court found bribery in July 2024, and the judgment became final against Privinvest in May 2026 when its appeal was dismissed. On October 21, 2026, the Court of Appeal upheld the joinder of Safa’s widow as a defendant, so Mozambique can pursue enforcement against her.

Latest development Oct 21, 2026

On October 21, 2026, the Court of Appeal dismissed Clara Martinez Thedy de Safa’s appeal against her joinder as a defendant ([2026] EWCA Civ 1349). It held that English proceedings can decide whether she inherited Iskandar Safa’s liabilities under Lebanese law, so Mozambique may pursue enforcement against her up to the value of her inheritance. The appeals of Safa’s two sons, who had disclaimed their inheritance, were allowed by consent.

Why it matters

The outcome determines who bears the loss from $2B of secretly guaranteed debt that preceded Mozambique’s 2016 default. With the judgment final against Privinvest, the open question is whether Mozambique can enforce it against the group’s assets, the Safa estate, and Safa’s widow.

Background

Beginning in 2013, Credit Suisse and VTB lent about $2B to three Mozambican state companies: ProIndicus, EMATUM, and MAM. The loans were nominally for tuna fishing and maritime security projects supplied by Privinvest. Mozambique guaranteed them in secret, without parliamentary approval. When the “hidden debts” surfaced in 2016, the International Monetary Fund (IMF) suspended support and Mozambique defaulted, triggering a deep economic crisis.

In 2019, the Republic of Mozambique sued Privinvest Shipbuilding SAL (Holding) and other Privinvest group companies, their owner Iskandar Safa, and Credit Suisse in London. In September 2023, the UK Supreme Court held that the claims fell outside the arbitration clauses in the supply contracts ([2023] UKSC 32). That ruling cleared the way for trial. Credit Suisse (by then UBS) settled on the eve of trial, which opened in the Commercial Court of the High Court of England and Wales in October 2023. Safa died in January 2024.

On July 29, 2024, after a 13-week trial, Knowles J found that Privinvest and Safa had paid bribes, including at least $7M to then-finance minister Manuel Chang. The court awarded Mozambique just over $825M in damages and an indemnity of roughly $1.5B, less about $421M in credits, for its ongoing liabilities to lenders and bondholders ([2024] EWHC 1957 (Comm)). In December 2024, Knowles J refused permission to appeal and stayed enforcement only on condition that Privinvest immediately pay £20M in costs. The Court of Appeal of England and Wales granted permission to appeal in April 2025, finding a real prospect of success, and the appeal was later listed for June 2026. A June 2025 order joined Safa’s widow, Clara Martinez Thedy de Safa, and his sons, Akram and Alejandro Safa, as defendants.

On May 14, 2026, the Court of Appeal dismissed the appeal because the Privinvest companies had failed to comply with the security conditions imposed on them. The judgment is now final against the group, and Mozambique’s recovery efforts against the estate and the group’s assets continue. In August 2026, the widow argued before the Court of Appeal that Lebanese inheritance law, not the English courts, should decide her liability as heir. Safa’s sons had disclaimed their inheritance (confirmed by a Lebanese court in June 2026), and Mozambique agreed that their appeals against joinder should be allowed. On October 21, 2026, the court dismissed the widow’s appeal and allowed the sons’ appeals by consent ([2026] EWCA Civ 1349).

Timeline 11 events

  1. Judgment
    Court of Appeal dismisses Safa widow’s joinder appeal

    The court upheld the June 2025 order joining Clara Martinez Thedy de Safa as Iskandar Safa’s heir, so Mozambique can seek enforcement against her. Safa’s sons’ appeals were allowed by consent after they disclaimed their inheritance.

    Attorney General of Mozambique succeeds in Safa family appealMozambique v Privinvest: Court of Appeal rejects challenge to joining Safa's widow over alleged liabilitiesMozambique Can Pursue Safa Widow In 'Tuna Bonds' Case

  2. Order
    Mozambique agrees Safa sons’ appeals against joinder should be allowed

    Counsel for Clara Safa told the Court of Appeal that the sons, Akram and Alejandro, had disclaimed their inheritance, as a Lebanese court confirmed in June 2026. Mozambique agreed that their appeals against their June 2025 joinder should be allowed.

    London appeal court hears Safa widow's bid to leave Mozambique's "hidden debts" case

  3. Hearing
    Court of Appeal hears Safa widow’s challenge to her joinder

    Clara Martinez Thedy de Safa, widow of Iskandar Safa, sought to overturn the June 2025 ruling adding her as a defendant. She argued that Lebanese inheritance law, not the English courts, should decide her liability as heir.

    London appeal court hears Safa widow's bid to leave Mozambique's "hidden debts" case

  4. Appeal
    Court of Appeal dismisses the appeal over unmet security conditions

    The judgment became final against the Privinvest companies. Recovery proceedings against the group and the Safa estate continue.

    360 Mozambique

  5. Appeal
    Court of Appeal grants Privinvest permission to appeal

    The court found a real prospect of success. The appeal was later listed for June 2026.

    Baird Maritime / Reuters

  6. Order
    Knowles J refuses permission to appeal

    The judge stayed enforcement only on condition that Privinvest immediately pay £20M in costs.

    African Law & Business

  7. Judgment
    Knowles J finds bribery and awards Mozambique over $825M plus indemnity

    The court held Privinvest and Safa liable for bribes paid to former finance minister Manuel Chang ([2024] EWHC 1957 (Comm)). The indemnity is roughly $1.5B, and about $421M in recoveries is credited.

    Brick Court ChambersSpotlight on Corruption

  8. Hearing
    Trial opens in Commercial Court after Credit Suisse settles

    Credit Suisse (by then UBS) settled on the eve of trial.

  9. Judgment
    UK Supreme Court allows claims to proceed to trial ([2023] UKSC 32)

    The court held that Mozambique’s bribery claims were not “matters” within the supply contracts’ arbitration agreements. No stay was available under section 9 of the Arbitration Act 1996.

    UK Supreme Court case page

  10. Filing
    Mozambique sues Privinvest, Safa and Credit Suisse in London
  11. Other
    Mozambique secretly guarantees $2B in loans to state companies

    Credit Suisse and VTB lent to ProIndicus, EMATUM, and MAM for Privinvest-supplied maritime projects. The guarantees lacked parliamentary approval, and default followed in 2016.

Experimental AI forecast

How it is made

Will Clara Martinez Thedy de Safa obtain permission to appeal her joinder to the UK Supreme Court by September 30, 2027?

  • Widow’s joinder becomes final63%
  • Still pending on September 30, 202717%
  • Supreme Court grants widow permission14%
  • Mozambique settles with Safa widow6%
Resolves by
Sep 30, 2027in 11 months
Record confidence
Medium

The widow’s joinder is most likely to become final, at 63%, by September 30, 2027. The UK Supreme Court grants only a minority of civil permission applications. Her best route now is contesting the value of her inheritance in the English proceedings, not a further appeal.

How it resolves. Resolves “joinder becomes final” if, by September 30, 2027, public records show that no permission application was made within time, or that the Court of Appeal and the UK Supreme Court refused permission to appeal [2026] EWCA Civ 1349. Resolves “permission granted” if the Supreme Court grants her permission to appeal. Resolves “settlement” if Mozambique and the widow publicly settle or Mozambique discontinues against her before either event. Otherwise resolves “still pending.”

Reasoning

Starting point. Applications for permission to appeal to the UK Supreme Court in civil cases after a Court of Appeal loss: The UK Supreme Court grants roughly 20% to 30% of civil permission applications. Many losing parties never apply.

The previous question resolved on October 21, 2026, when the Court of Appeal upheld the joinder, so this forecast asks a new question and does not compare numbers. The next step is whether the widow seeks and obtains Supreme Court permission. The base rate for civil permission grants is about 20% to 30%, and many parties do not apply. The record does not show whether the Court of Appeal refused permission at hand-down. Her issue, whether English courts can decide heirship liability under Lebanese law, has some cross-border importance, which supports a modest chance of a grant. Against that, an appeal adds cost while her exposure is capped at the value of her inheritance. The sons’ disclaimers suggest the family is managing exposure through Lebanese law rather than further English appeals. Settlement is possible but unlikely soon, since Mozambique holds a final judgment and has shown it will pursue recovery. Supreme Court permission decisions can take six months or more, so a pending result remains a real alternative.

Low UK Supreme Court grant rate for civil permission applications · Cross-border succession issue may raise general public importance · Widow’s liability capped at value of her inheritance · Record silent on whether permission was sought at hand-down · Supreme Court permission decisions often take several months

Previous forecast: correct “How will the Court of Appeal rule on Clara Martinez Thedy De Safa’s challenge to the June 2025 order joining her as a defendant, by March 31, 2027?” (Sep 25, 2026). On October 21, 2026, the Court of Appeal dismissed Clara Martinez Thedy de Safa’s appeal and upheld the June 2025 order joining her as Iskandar Safa’s heir. Her sons’ appeals were allowed by consent after they disclaimed their inheritance. It put “Court of Appeal upholds widow’s joinder” at 57%. Track record

Generated automatically by Claude Opus 5.5 on Oct 23, 2026 from this case’s record on this site, and published without editorial review. The probabilities are the model’s judgment, not measured frequencies, and they are scored publicly as cases resolve. Not legal or investment advice. How the forecasts are made