Action required: worldwide freezing orders and Russian-situated assets — new compliance obligation

Alert: Action required — worldwide freezing orders and Russian-situated assets Effective: 15 January 2026

Foreign creditors who have obtained worldwide freezing orders (WFOs) covering Russian-situated assets are now subject to a more demanding compliance monitoring standard. Courts in England and Wales, and in other jurisdictions where WFOs are routinely granted, have sharpened their scrutiny of whether creditors took reasonable steps to police WFO compliance across all named jurisdictions — including Russia. Creditors who cannot demonstrate active monitoring of their Russian asset position risk adverse findings on contempt applications and may jeopardise their broader enforcement strategy.

This obligation sits on the creditor, not only on the respondent. Where the WFO extends to assets held in Russia — whether bank deposits, shareholdings in Russian entities, real estate, or receivables from Russian counterparties — the creditor's legal team is expected to have taken concrete steps to document the Russian asset position, serve appropriate notice on Russian-based entities within scope, and instruct qualified Russian counsel to monitor compliance on the ground. Failure to establish this record before a contempt or enforcement hearing can materially weaken the creditor's position before the issuing court.

The practical gap arises because Russian law does not give direct effect to foreign injunctions. A WFO issued in London or Amsterdam does not restrain a Russian entity as a matter of Russian domestic law. The compliance obligation therefore falls on the respondent's conduct in Russia and on the creditor's ability to demonstrate, through Russian-counsel reporting, that the asset position was tracked and that any dissipation was identified and notified promptly. Creditors who have not yet established that Russian-counsel link are carrying an unquantified risk at the enforcement stage.

Recommended action:

1. Review the asset schedule in your existing WFO to identify all Russian-situated assets by category.
2. Instruct Russian counsel immediately to document the current status of those assets and confirm the entities or individuals within scope of the order's compliance obligations.
3. Establish a reporting protocol with Russian counsel — covering asset monitoring, early-warning triggers for dissipation, and the preservation of evidence for use before the issuing court.

For foreign creditors enforcing worldwide freezing orders over Russian-situated assets, the window for establishing a defensible compliance record is now. To discuss your position in confidence, contact us at info@vetrovpartners.com or reach the team directly on WhatsApp / Telegram: +7 (983) 510-38-76.

Further reading on WFOs and Russian-situated assets:

• Worldwide freezing orders and Russian-situated assets: a legal overview
• A practical guide to worldwide freezing orders over Russian assets
• Asset Tracing & Recovery practice

About Vetrov & Partners Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 for eight consecutive years. The firm's asset tracing and recovery practice advises foreign creditors on preserving and enforcing claims against Russian-situated assets, including monitoring compliance with worldwide freezing orders and coordinating with foreign counsel on cross-border enforcement.

Enquiries: info@vetrovpartners.com | WhatsApp / Telegram: +7 (983) 510-38-76 | t.me/vitvetcom

— Elizaveta Razina Senior Lawyer, Practice Lead — IP Enforcement, Vetrov & Partners vetrovpartners.com/razina/

This alert is for informational purposes only and does not constitute legal advice. Vetrov & Partners is a Russian-qualified law firm. Contact info@vetrovpartners.com for advice on your specific situation.