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Investment treaty awardAssets attached

Naftogaz v. Russia

Crimean energy assets

Headline amount
$4.2BPrincipal
Respondent
RussiaState
Awarded
Apr 12, 2023Final award. Partial award February 22, 2019
Status
Assets attachedAssets frozen or attached, nothing realized

Latest development Oct 26, 2026

The D.D.C. denied Russia’s motion to dismiss. A Norwegian ruling on the vessel arrest is pending.

The award

Amount awarded
$4.22B plus interest
Current estimate
More than $6B with interest and costs (Covington, via Reuters, September 2026)
Award holder
Naftogaz of Ukraine, Chornomornaftogaz, Ukrgasvydobuvannya, Ukrtransgaz, Ukrtransnafta and Gaz Ukraiiny
Respondent
Russian Federation
Forum
PCA 2017-16 · Russia–Ukraine BIT · UNCITRAL · seat The Hague

Challenges

The partial award was partly set aside for investments made before 1992 (Hague Court of Appeal, July 19, 2022, upheld by the Supreme Court on December 6, 2024). On the final award, the Hague Court of Appeal said in an interim ruling (reported October 15–16, 2026) that it must be partly set aside for assets with no post-1991 investment. The size of the reduction and the final ruling are pending.

Enforcement

Norway: the Nord-Troms og Senja District Court ordered an arrest on August 31, 2026. On September 2, 2026, the Governor of Svalbard arrested the Russian expedition vessel Professor Molchanov at Barentsburg, and attachments followed over the Russki Dom in Longyearbyen, 62 snowmobiles, 15 cars and four bank accounts. The Oslo District Court authorized the attachment of five Oslo properties in October 2026. France: exequatur and judicial mortgages of about €120M (April 2025). Austria: more than 20 properties worth over €120M encumbered (August 2025). Finland: provisional attachment up to the full award (June 2025) and €3.7M seized (June 2026). England: recognition (December 2023). United States: the D.D.C. (23-cv-1828) refused a stay on July 17, 2026, and denied Russia’s motion to dismiss on October 26, 2026.

Recovered to date

Nothing realized. €3.7M seized in Finland.

Notes

The vessel’s owner is not named in the Governor of Svalbard’s release.