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Celestial Aviation Trading Ireland Ltd & Ors v Volga-Dnper Logistics BV (Re Costs) [2025] EWHC 1394 (Comm) (06 June 2025)

Source: Open mirrored case · Original bailii.org

Sanctions ✓ Geo ✓

Executive Summary

  • The England and Wales High Court dismissed the Defendant Volga-Dnper Logistics B.V.’s Variation Application and ordered it to pay Claimants’ costs summarily assessed at £134,484.96 within 14 days.
  • The Defendant sought to postpone payment pending an OFSI licence or removal of sanctions prohibitions under the UK Russia Regulations.
  • The Court rejected this, finding no real risk of breach from payment instructions made outside the UK or receipt of funds in UK bank accounts.
  • The Claimants gave assurance not to pursue contempt proceedings if payment was delayed.
  • The Court emphasized the limited relevance of UK sanctions in this context and ordered prompt payment.

Sanctions Highlights

  • Defendant argued payment would breach UK Russia Regulations without an OFSI licence.
  • Court found no substantial risk of sanctions breach from payment execution or receipt.
  • UK sanctions were deemed of limited relevance given the Defendant’s asset situation and the nature of payment instructions.
  • Assurance from Claimants mitigated concerns over enforcement actions for non-payment.

Emerging Risks

  • Potential for litigants to invoke sanctions as a defense to delay or avoid court-ordered payments.
  • Ambiguity remains around cross-border payment instructions and sanctions compliance.
  • Risk of increased litigation complexity where sanctions regimes intersect with commercial disputes.
  • Possible precedent for courts to scrutinize sanctions claims closely and require concrete evidence of breach risk.

Geopolitical Impact

  • Case underscores ongoing tensions between UK sanctions policy and Russian entities amid geopolitical conflict.
  • Highlights UK judiciary’s role in enforcing sanctions while balancing commercial justice.
  • Reflects UK’s firm stance on sanctions enforcement but pragmatic approach to avoid undue disruption.
  • Reinforces UK’s legal framework as a tool in geopolitical pressure on Russia.

Economic Intelligence

  • Defendant’s liabilities exceed assets, complicating payment capacity under sanctions constraints.
  • Sanctions create friction in cross-border commercial transactions, increasing legal and financial risks.
  • The ruling supports creditor rights despite sanctions, potentially influencing risk assessments in aviation and logistics sectors.
  • May affect future contract negotiations involving Russian counterparties under UK jurisdiction.

Strategic Recommendations

  • Parties engaged with sanctioned entities should seek early legal advice on sanctions compliance and payment mechanisms.
  • Claimants should consider providing assurances to mitigate defendants’ sanctions fears and expedite enforcement.
  • Monitor evolving OFSI licensing policies and sanctions regulations for impact on litigation and payments.
  • Legal teams should prepare to address sanctions defenses with detailed factual and regulatory analysis.
  • Businesses should reassess exposure to Russian counterparties in light of judicial interpretations limiting sanctions as payment barriers.

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**Source Notes:**

Sanctions Intelligence Digest, England and Wales High Court [2025] EWHC 1394 (Comm)

https://empyreanprotocol.com/litigation/view/www.bailii.org/ew/cases/EWHC/Comm/2025/1394.html

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