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CAFI - Commodity & Freight Integrators DMCC v GTCS Trading DMCC [2025] EWHC 1350 (Comm) (03 June 2025)

Source: Open mirrored case · Original bailii.org

Sanctions ✓ Geo ✓

IntelBrief: Sanctions Intelligence Digest

1) Executive Summary

  • The case involves CAFI (buyer) and GTCS (seller) disputing contracts for Russian milling wheat amid US sanctions on Russia.
  • Two contracts were executed: the First Contract (March 2022) at US$465/mt and the Second Contract (March 2022) at US$440/mt, with the latter terminating the former.
  • CAFI claimed inability to pay under the First Contract due to US sanctions; GTCS disputed this and terminated the contract for anticipatory breach.
  • Arbitration initially dismissed GTCS’s claim; an Appeal Award reversed this, ordering CAFI to pay US$700,000 damages.
  • The High Court found procedural irregularities and jurisdictional issues, setting aside parts of the Appeal Award related to waiver and damages, potentially remitting for redetermination.

2) Sanctions Highlights

  • CAFI cited US sanctions against Russia as the reason for non-payment under the First Contract.
  • The contract explicitly excused non-performance due to sanctions, supported by evidence from financial institutions refusing payment.
  • Sanctions directly impacted contract performance, payment flows, and dispute resolution.
  • The case underscores the legal complexity of sanctions compliance in commodity trading contracts.

3) Emerging Risks

  • Risk of contractual disputes arising from sanctions-related non-performance claims.
  • Arbitration jurisdictional challenges when multiple contracts with separate arbitration clauses exist.
  • Potential for protracted litigation or arbitration due to unclear contractual termination and waiver provisions.
  • Financial institutions’ refusal to process payments under sanctions regimes increases transactional risk.

4) Geopolitical Impact

  • The dispute centers on Russian wheat exports to Egypt, highlighting the intersection of US sanctions policy and global commodity trade.
  • Egypt’s role as the Mediterranean port of discharge underscores its strategic position in wheat supply chains.
  • The US sanctions regime influences commercial relations between Russian exporters and Middle Eastern buyers.
  • The case reflects broader geopolitical tensions affecting trade flows and contract enforcement.

5) Economic Intelligence

  • The price renegotiation from US$465 to US$440 per metric ton reflects market adjustments amid sanctions and payment difficulties.
  • The cargo volume of 28,000 metric tons represents significant trade value (~US$12 million payment confirmed).
  • Delays and disputes over payment and delivery terms may disrupt supply chains and increase costs.
  • Arbitration outcomes affect commercial confidence and risk premiums in sanctioned commodity markets.

6) Strategic Recommendations

  • Parties engaged in trade with sanctioned entities should incorporate clear sanctions clauses and payment contingencies.
  • Legal counsel should ensure arbitration clauses cover all related contracts to avoid jurisdictional gaps.
  • Financial institutions must maintain robust compliance checks to mitigate sanctions exposure.
  • Buyers and sellers should proactively negotiate dispute resolution mechanisms tailored to sanctions-related risks.
  • Monitoring geopolitical developments in US-Russia relations is critical for anticipating trade disruptions.

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**Source Notes:**

Case Title: *Sanctions Intelligence Digest*

Link: https://empyreanprotocol.com/litigation/view/www.bailii.org/ew/cases/EWHC/Comm/2025/1350.txt

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