What happened
In mid-2024, proceedings were brought before the Higher Regional Court of Berlin to recognize an award of the ICAC at the Russian Chamber of Commerce and Industry. The German debtor objected, arguing that the arbitration clause had never been concluded and that recognition would violate public policy (EU sanctions). In April 2025, the court found no grounds to apply sanctions and approved a settlement agreement, which was subsequently performed. In December 2025, the Ontario Superior Court of Justice recognized and enforced an ICAC award, finding that it did not contravene Canadian public policy and rejecting the debtor’s motions to delay the proceedings. In October 2025, the Ras Al Khaimah court of first instance recognized an ICAC award, and in December 2025 and February 2026 the appellate and cassation courts upheld that decision.
Why it is notable
Among the few cases since 2022 in which ICAC awards were recognized in three foreign jurisdictions at once (the EU, Canada, and the UAE) despite sanctions.