The Court of Appeal affirmed its earlier decision granting UniCredit an injunction enjoining RusChem from continuing the court proceedings it had commenced against UniCredit in Russia. The Court held first that English law – the law contractually chosen to govern the underlying contract – applied to the arbitration clause therein, in the absence of a clear indication that the parties meant a different law to apply. In particular, the choice for a French seat was not such an indication. The Court then found that, notwithstanding the strong international policy of giving effect to agreements to arbitrate disputes, as embodied in Art. II(3) of the  New York Convention, there were strong reasons in this case to displace the prima facie entitlement to enforce the contractual bargain for arbitration. Pursuant to Art. 248 of the Arbitrazh Procedural Code of the Russian Federation, introduced in 2020, arbitrazh courts have exclusive jurisdiction over disputes between Russian and foreign persons arising from foreign sanctions (as was the case here), so that the arbitration clause was unenforceable in Russia. Since under the applicable English law the arbitration agreement was valid, and RusChem’s claim fell squarely within its scope, it was a breach of contract for RusChem to pursue its claim in the Russian courts.