What happened
On September 25, 2024, an LCIA tribunal ordered RTI Limited and RUSAL, as guarantor, to pay approximately €214M under early-terminated currency swaps to OWH SE i.L. (formerly VTB Bank (Europe), in liquidation under BaFin supervision). In 2025 and 2026, the courts of Jersey, England, and the Netherlands rejected the debtors’ sanctions objections and enforced the award, and the Telangana High Court prohibited the transfer of shares in the Indian company Pioneer Aluminium. On May 28, 2026, on RUSAL’s own application, the Arbitrazh Court of the Kaliningrad Region refused to recognize the LCIA award in Russia, finding that enforcement would amount to expropriation because the funds would remain under BaFin’s control. In parallel, RUSAL commenced investment arbitration against Germany over the compulsory liquidation of VTB Europe.
Why it is notable
A rare tactic: the debtor itself applied for recognition and enforcement of the award made against it, in order to use the Russian court’s refusal as an argument against enforcement abroad. As a result, the prevailing party is successfully obtaining recognition of the LCIA award in four jurisdictions, while the Russian court refused to recognize and enforce the LCIA award as contrary to Russian public policy.