JPMorgan v. VTB Bank

After sanctions were imposed on VTB Bank, its counterparty JPMorgan froze the balances on the bank’s accounts under the ISDA Master Agreement between the banks. In October 2024, VTB filed tort claims against JPMorgan group companies in the Arbitrazh Court of St. Petersburg and the Leningrad Region under Article 248.1 of the Russian Arbitrazh Procedure Code. Relying on the LCIA arbitration clause in that agreement, JPMorgan obtained an anti-suit injunction from the English court. On June 5, 2025, the High Court of England and Wales granted final injunctions, finding the claims brought in Russia vexatious and oppressive, and on May 12, 2026, the Court of Appeal of England and Wales dismissed VTB’s appeal, confirming that JPMorgan group companies may rely on the arbitration clause even where they are not themselves parties to the agreement with VTB. On June 19, 2026, the Russian court dismissed VTB’s claim without considering the merits, noting among other things that the Russian bank had not objected to this.

English courts confirmed protection against Russian claims under Article 248.1 of the Russian Arbitrazh Procedure Code, which led to the claim being dismissed in Russia without consideration of the merits. The Court of Appeal extended the LCIA arbitration clause to affiliates of the defendant bank. The court justified this approach as a way to counter tort claims by Russian companies against affiliates of foreign defendants, which it regarded as attempts to circumvent jurisdiction clauses.