A worldwide freezing order granted by a foreign court does not bind Russian courts directly. Russia has not acceded to treaties providing for automatic recognition of foreign interim relief. At the cross-border tracing stage, a creditor holding a worldwide freezing order against Russian-situated assets must therefore pursue two parallel tracks: enforcing disclosure obligations within the WFO jurisdiction, and conducting an independent Russian asset identification and restraint process. Each track has its own procedural logic, and delay on either one carries real dissipation risk.
The first track — operating within the WFO jurisdiction — involves using the order to compel disclosure from the respondent and from third parties holding assets or information on their behalf. This is typically handled by lead counsel in the issuing jurisdiction. The information obtained feeds directly into the Russian track.
The second track — the Russian asset freeze and tracing stage — proceeds as follows. Asset identification begins with searches of publicly accessible Russian registries: Rosreestr for real property and mortgage interests, the EGRUL corporate registry for shareholdings and directorships, and the bailiff service database for existing enforcement proceedings. These searches are accessible to any party without a Russian court order and form the evidential foundation for subsequent steps.
Once assets are identified, a creditor seeking interim restraint must apply for securing measures (обеспечительные меры) before a Russian arbitrazh court. This application is ordinarily filed simultaneously with, or immediately after, commencing substantive proceedings in Russia. Russian courts assess securing measure applications on an expedited basis, but the application must demonstrate a real risk of asset dissipation — not merely assert it. Courts have broad discretion on this question, and the strength of the supporting evidence materially affects the outcome.
For foreign creditors who have not yet commenced Russian proceedings, the window between obtaining the WFO and the respondent's awareness of it is often the only realistic opportunity to act. Creditors who allow that window to close without initiating Russian steps risk finding assets dissipated or transferred before any Russian restraint order is in place.
For specific guidance on cross-border tracing of Russian assets and coordinating worldwide freezing order strategy with Russian interim relief, see Worldwide Freezing Orders and Russian-Situated Assets and A Practical Guide to Worldwide Freezing Orders in the Russian Context.
The firm's Asset Tracing & Recovery practice advises foreign creditors at each stage of this process, including registry searches, securing measures applications, and coordination with lead counsel in the WFO jurisdiction.
If you are holding a worldwide freezing order and need to identify or restrain Russian-situated assets — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76
— Elizaveta Razina Senior Lawyer, Practice Lead — IP Enforcement, Vetrov & Partners vetrovpartners.com/razina/
Elizaveta Razina leads the firm's intellectual property practice, representing foreign trademark owners in infringement proceedings before Russian state courts and the IP Court. She has been with the firm since 2012 and holds a degree from Novosibirsk State University (2013). She advises on anti-counterfeiting strategy and parallel import controls.
This publication is provided for informational purposes only and does not constitute legal advice under Russian or any other applicable law. The information herein should not be relied upon as a substitute for professional legal counsel tailored to your specific circumstances. Vetrov & Partners is a Russian-qualified law firm. For matters governed by foreign law or requiring local admission in another jurisdiction, we collaborate with trusted counsel in the relevant jurisdiction. For advice regarding your particular situation, please contact info@vetrovpartners.com.