Former majority shareholders of Yukos Oil Company won the largest arbitral awards in history, roughly $50B, against Russia for the expropriation of the oil giant, and have spent the decade since fighting to enforce them.
LATEST DEVELOPMENT · MAR 2, 2026
On 17 October 2025, the Dutch Supreme Court issued a final ruling rejecting Russia’s last remaining challenge to the awards, conclusively ending set-aside proceedings in the Netherlands. On 2 March 2026, England’s High Court (Commercial Court) dismissed Russia’s public-policy and fraud-based objections and granted the shareholders leave to enforce the awards, now valued at over $65B with accrued interest, against Russian assets in the UK, though it declined to enforce the costs award.
BACKGROUND
The claimants, holding companies of the GML group that together controlled about 70% of Yukos, alleged that Russia destroyed the company through tax reassessments, forced auctions and the imprisonment of its executives, in breach of the Energy Charter Treaty. In July 2014, a tribunal seated in The Hague found Russia liable for expropriation and awarded approximately $50B plus costs, by an order of magnitude the largest arbitration award ever rendered.
Russia refused to pay and challenged the awards at the seat. The Hague District Court set them aside in 2016. The Hague Court of Appeal reinstated them in 2020. The Dutch Supreme Court rejected most of Russia’s cassation grounds in 2021, and the Amsterdam Court of Appeal dismissed Russia’s remaining fraud-based challenge in February 2024. In October 2025, the Dutch Supreme Court dismissed Russia’s final cassation appeal, definitively ending the set-aside litigation. Enforcement litigation continues in the United States, the United Kingdom, Singapore and elsewhere, with post-award interest pushing the total above $65B.
TIMELINE
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MAR 2, 2026ENFORCEMENTEnglish Commercial Court grants leave to enforce Yukos awards in the UKMr Justice Bright of the English Commercial Court dismissed Russia’s public-policy objections based on alleged historic fraud/corruption and granted the Yukos shareholders leave to enforce the arbitration awards (worth over $50B plus compound interest, reported as exceeding $65-66 billion) against Russian assets in the UK. The court declined to enforce the costs portion of the awards.
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MAR 2, 2026ENFORCEMENTEnglish Commercial Court grants leave to enforce awards in the UKMr Justice Bright of the English Commercial Court dismissed Russia’s fraud and public-policy objections under section 103(3) of the Arbitration Act 1996 and granted the Yukos shareholders leave to enforce the arbitration awards (worth over $50B, more than $65B with interest) against Russian assets in the UK, while declining to enforce the costs portion of the awards.
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MAR 2, 2026ENFORCEMENTEnglish Commercial Court clears enforcement of the awardsBright J rejected Russia’s public-policy objections and held the shareholders entitled to enforce, except for c. $50M in arbitration costs ([2026] EWHC 456 (Comm)).
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OCT 17, 2025JUDGMENTDutch Supreme Court issues final rejection of Russia’s last challenge to the awardsThe Dutch Supreme Court rejected Russia’s final remaining legal challenge to the $50B arbitration awards, conclusively ending the set-aside proceedings in the Netherlands with no further Dutch remedies available to Russia.
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OCT 17, 2025APPEALDutch Supreme Court dismisses Russia’s final set-aside challenge, ending annulment proceedingsThe Dutch Supreme Court rejected Russia’s last remaining ground for setting aside the $50B ECT awards, bringing the decade-long Dutch set-aside litigation to a definitive close.
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OCT 17, 2025JUDGMENTDutch Supreme Court dismisses Russia’s final appeal, ending the set-aside sagaThe awards became final and unassailable at the seat. With accrued interest their value exceeds $65B.
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AUG 5, 2025APPEALD.C. Circuit vacates and remands the US enforcement rulingThe court held that the district court must itself determine whether the FSIA arbitration exception applies, including what preclusive effect the Dutch judgments carry. Russia then petitioned the US Supreme Court.
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JUN 2025APPEALUK Supreme Court refuses Russia permission to appeal on immunityThe refusal left standing the Court of Appeal’s February 2025 ruling ([2025] EWCA Civ 108) that Russia is estopped from re-arguing the jurisdictional points decided by the Dutch courts.
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FEB 20, 2024JUDGMENTAmsterdam Court of Appeal dismisses Russia’s fraud challenge
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NOV 1, 2023JUDGMENTEnglish High Court holds Russia not immune from enforcement proceedingsCockerill J gave effect to an issue estoppel arising from the Dutch judgments on the existence of an arbitration agreement ([2023] EWHC 2704 (Comm)).
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NOV 5, 2021APPEALDutch Supreme Court rejects most of Russia’s cassation groundsOne fraud-related ground remanded to the Amsterdam Court of Appeal.
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FEB 18, 2020APPEALHague Court of Appeal reinstates the awards
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APR 20, 2016JUDGMENTHague District Court sets aside the awards
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JUL 18, 2014AWARDTribunal awards claimants ~$50BThe PCA-administered tribunal found Russia expropriated Yukos in breach of the ECT and issued the largest arbitral awards in history.
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NOV 30, 2009PROCEDURALInterim awards uphold the tribunal’s jurisdictionThe tribunal held that the ECT applied provisionally to Russia, allowing the claims to proceed.
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FEB 2005FILINGArbitrations commenced under the Energy Charter Treaty