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Google LLC & Anor v NAO Tsargrad Media & Ors [2025] EWHC 94 (Comm) (22 January 2025)

Source: Open mirrored case · Original bailii.org

Sanctions ✓ Geo ✓

Executive Summary

This case involves Google LLC and Google Ireland Limited seeking anti-enforcement injunctions to block recognition and enforcement of Russian court judgments obtained by Tsargrad Media, NFPT, and TV-Novosti. The Russian judgments relate to disputes over Google’s suspension of services to Tsargrad, a media entity indirectly majority-owned by sanctioned Russian oligarch Konstantin Malofeyev. The Russian courts imposed unprecedented astreinte penalties on Google for non-compliance, linked to Russian sanctions law (Law No. 171-FZ). The English High Court ruled in favor of Google, emphasizing exclusive English jurisdiction clauses and rejecting enforcement of the Russian judgments outside Russia.

Sanctions Highlights

  • Konstantin Malofeyev, majority owner of Tsargrad, is sanctioned by the EU (Decision 2014/508/CFSP) and designated by OFAC for actions destabilizing Ukraine.
  • Google ceased services to Tsargrad in July 2020 to comply with US sanctions law.
  • Russian courts imposed extraordinarily high astreinte penalties on Google under Law No. 171-FZ, a statute linked to enforcement against sanctioned parties.
  • The case highlights the use of sanctions-related asset freezes and enforcement attempts globally.
  • Enforcement efforts extend beyond Russia, raising OFAC and international sanctions compliance concerns.

Emerging Risks

  • Increasing use of Russian courts to impose punitive financial penalties on foreign companies complying with Western sanctions.
  • Risk of extraterritorial enforcement of Russian judgments in multiple jurisdictions, threatening multinational corporations.
  • Potential for escalating legal conflicts between jurisdictions enforcing sanctions and those resisting foreign judgments perceived as politically motivated.
  • Growing complexity in navigating jurisdictional disputes involving sanctions compliance and cross-border enforcement.

Geopolitical Impact

  • The case underscores tensions between Western sanctions regimes (US, EU, UK, Canada) and Russian retaliatory legal measures.
  • Highlights the geopolitical divide involving Russia and Western-aligned countries, including India, China, Turkey, and others where enforcement attempts may arise.
  • Demonstrates the use of legal mechanisms as tools of geopolitical influence and economic pressure.
  • Reflects broader challenges in international law and dispute resolution amid ongoing Russia-Ukraine conflict and sanctions enforcement.

Economic Intelligence

  • Google’s suspension of services to Tsargrad resulted in seizure of assets worth over $50 million in Russia.
  • The unprecedented scale of astreinte penalties (up to billions of rubles) signals heightened financial risks for foreign firms operating in or with Russia.
  • Enforcement attempts outside Russia threaten to disrupt global digital and advertising markets.
  • The case may deter foreign investment and complicate operations for companies subject to conflicting jurisdictional claims and sanctions laws.

Strategic Recommendations

  • Multinational companies should rigorously review jurisdiction clauses and arbitration agreements to preempt enforcement risks.
  • Enhance sanctions compliance programs to include monitoring of foreign court judgments and potential extraterritorial enforcement.
  • Legal teams should prepare to seek anti-enforcement relief in jurisdictions recognizing exclusive English jurisdiction clauses.
  • Engage in proactive geopolitical risk assessments focusing on Russia-West legal conflicts and emerging sanctions-related litigation.
  • Coordinate with governmental and regulatory bodies (OFAC, EU sanctions authorities) to align corporate responses and mitigate enforcement exposure.

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**Source Notes:** Sanctions Intelligence Digest, [https://empyreanprotocol.com/litigation/view/www.bailii.org/ew/cases/EWHC/Comm/2025/94.html](https://empyreanprotocol.com/litigation/view/www.bailii.org/ew/cases/EWHC/Comm/2025/94.html)

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