Alert: important development in third-party disclosure orders in Russian proceedings at the cross-border tracing stage

Alert: Important development in third-party disclosure orders in Russian proceedings at the cross-border tracing stage Effective: October 2026

Russian arbitrazh courts have raised the evidentiary threshold for third-party disclosure orders at the cross-border tracing stage. Creditors whose applications previously succeeded on broadly framed information requests are now encountering procedural resistance that risks derailing recovery timelines.

Foreign creditors tracing assets across jurisdictions rely on third-party disclosure orders directed at Russian banks, registries, and professional service providers who hold records of a debtor's assets. Courts have increasingly required applicants to demonstrate, at the application stage, the specific category of information sought, the particular nexus between the third party and the debtor's assets, and proportionality between the disclosure sought and the recovery objective. Applications that do not meet this standard are now being declined or returned for amendment – a delay that can be critical when assets are at risk of dissipation. Creditors engaged in live cross-border tracing efforts should treat the procedural scaffolding of any pending or planned disclosure application as a live compliance risk.

Recommended action:

1. Review any pending third-party disclosure applications filed in Russian proceedings to confirm they specify the information category, the third-party nexus, and the proportionality basis with sufficient particularity under the current standard.

1. Where applications have already been declined or returned, assess whether amendment and resubmission is procedurally available within the applicable timeframe.

1. Engage Russian-qualified asset-tracing counsel before filing new disclosure applications – the current standard requires a more granular evidentiary scaffold than was previously the norm. See the firm's Asset Tracing & Recovery practice page for further context, and the related briefings at Third-Party Disclosure Orders in Russian Proceedings and A Practical Guide to Third-Party Disclosure Orders.

Speak to our team — info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

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 third-party disclosure applications, cross-border tracing, and enforcement proceedings before Russian courts.

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

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.

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