UNITED KINGDOM 2026-2

Jersey Court of Appeal,15 December 2025, Decision No. [2025] JCA 327

(RTI Limited v. OWH SE i.L.)

15 - 12 - 2025

UNITED KINGDOM 2026-2

Yearbook Yearbook Commercial Arbitration, S. W. Schill (ed.), Vol. LI (2026)
Jurisdiction United Kingdom
Summary

The Court of Appeal granted exequatur of an LCIA award, holding that payment under the award would not breach Jersey’s Sanctions Law 2019, because OWH SE, the German subsidiary of a bank owned by the Russian Federation, was not itself a designated entity for the purposes of the sanctions issued following Russia’s invasion of Ukraine.

Related topics
101

The court discusses the determination and relevance of the place where the award was made (in a foreign State or another contracting State.

Award made in the territory of another (Contracting) State (paragraphs 1 and 3 - first or "reciprocity" reservation)
524

Public policy: The court discusses the effect of other alleged violations of public policy on the recognition and enforcement of an arbitral award, such as contradictory reasons, manifest disregard of the law (US), etc.

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UNITED KINGDOM 2026-2