Power Machines v. PetroVietnam

In 2019, Power Machines, a sanctioned company, commenced SIAC arbitration against the Vietnamese state-owned corporation PetroVietnam over the halt in construction of the Long Phu 1 thermal power plant after the company was added to the U.S. SDN list. On November 30, 2023, the tribunal found the termination of the EPC contract lawful, dismissed a $3.5B counterclaim, and awarded Power Machines over $500M excluding interest. The arbitrators noted that U.S. sanctions do not constitute force majeure. In 2024, the High Court of Singapore, rather than setting the award aside in full, remitted it to the arbitrators for further consideration, while the Moscow Arbitrazh Court recognized and enforced the award in Russia despite its “temporary” annulment at the seat. On October 10, 2025, after the arbitrators had already issued a new award following the remission, the Court of Appeal of Singapore finally set aside certain parts of the award. Despite the award’s recognition in Russia, the Singapore courts found that it had been made in breach of procedural principles and was contrary to Singapore public policy. In July 2026, the Russian court set aside its ruling recognizing the SIAC award on the basis of new circumstances, which in the court’s view include the judgment of the Court of Appeal of Singapore.

The first publicly known win by a sanctioned Russian company in international arbitration after 2022. The SIAC tribunal expressly stated that U.S. sanctions do not constitute force majeure, but the Singapore courts disagreed with the award on procedural grounds.