Worldwide freezing orders and Russian-situated assets: key developments in 2026

For a foreign creditor who has obtained a worldwide freezing order from an English, Dutch, or other European court, the question of how that order reaches Russian-situated assets has grown materially more complex in the opening months of 2026. Russian courts do not give automatic effect to foreign interim measures, and the procedural routes for achieving the functional equivalent of a freeze over Russian assets have continued to evolve — sometimes in directions that close previously available options, sometimes in ways that open new ones. This analysis sets out the principal developments, their practical significance for foreign creditors, and the steps that experienced practitioners would prioritise at this stage.

The central legal position has not shifted: Russia is not a party to any multilateral convention that provides for the direct enforcement of foreign interim relief, and Russian procedural law does not recognise a foreign freezing order as an executable instrument in its own right. What has evolved in early 2026 is judicial practice on two adjacent questions — both of which matter significantly to foreign creditors with Russian-situated assets.

First, Russian arbitrazh courts have continued to develop their approach to domestically-granted interim measures sought in parallel to, or in support of, foreign arbitration proceedings. The prevailing approach across a number of circuit courts is to treat a valid arbitration agreement as a relevant factor — though not a determinative one — when assessing whether to grant interim relief over Russian assets. Creditors who can demonstrate both an arbitration clause and a prima facie arguable claim have, in the majority of cases reviewed by the firm, encountered a more receptive judicial environment than those relying solely on a pending foreign court action.

Second, and of greater concern to foreign trade creditors, is the continued tightening of procedural requirements around the security that a claimant must lodge when seeking an interim measure in Russian proceedings. In the past twelve months, courts in several circuits have applied a stricter proportionality test — requiring creditors to demonstrate that the measure sought is calibrated to the specific asset at risk, not simply to the maximum value of the claim. The practical effect is that broad-form freezes, which more closely resemble a conventional worldwide freezing order, are encountering more rigorous judicial scrutiny than targeted asset-specific measures.

"[CTA bridge]"

If you hold a worldwide freezing order and are assessing its reach over Russian-situated assets, make an enquiry with our asset tracing and recovery team: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

The developments described above have uneven impact across creditor types, and the distinction matters when planning enforcement strategy.

Trade creditors holding unsecured claims are most exposed. Without a proprietary or security interest in identified Russian assets, the route to effective interim relief runs through the Russian courts' interim measures jurisdiction — which, as described, has become more exacting. For this group, the risk of delay between obtaining a foreign order and achieving any practical hold over Russian assets has increased. Foreign creditors who delay initiating parallel Russian proceedings risk the debtor dissipating, transferring, or restructuring its Russian asset base before any domestic measure is in place — a window that Russian insolvency law can close once a bankruptcy petition is filed, but only if the creditor is already engaged in those proceedings.

Secured creditors — those holding a pledge or mortgage over specific Russian-situated assets — occupy a different position. Their enforcement rights are governed by the terms of the security instrument and Russian property law, and they are generally not dependent on the worldwide freezing order regime to preserve their position. The principal risk for this group lies in insolvency proceedings overtaking their enforcement timeline, which makes early engagement with Russian counsel a structural necessity rather than a precautionary step.

Institutional creditors and distressed-debt purchasers, who often acquire claims after the debtor's difficulties are already apparent, face the most compressed timelines. By the time a worldwide freezing order is obtained in a foreign court, Russian-situated assets may already be subject to competing claims, pending insolvency proceedings, or prior-ranking security. The practical guidance for this group is addressed in the section below.

For those navigating the broader restructuring and insolvency landscape, the firm's Restructuring & Insolvency practice provides a complementary analysis of how creditor rights are prioritised once Russian insolvency proceedings have commenced. The firm's Asset Tracing & Recovery practice sets out the full procedural framework.

Three procedural priorities emerge from the current landscape, each addressing a distinct risk point.

The first priority is establishing a parallel Russian proceedings track as early as possible. Foreign creditors who have obtained or are seeking a worldwide freezing order should simultaneously assess whether a claim can be filed in the competent Russian arbitrazh court or whether the arbitration agreement permits a parallel domestic interim measures application. The procedural clock in Russian proceedings does not pause while foreign proceedings continue, and courts have in practice denied late-stage interim applications where the creditor could demonstrably have applied earlier.

The second priority is asset identification. A worldwide freezing order without a clear picture of the Russian asset landscape is an instrument of limited practical value in the Russian context. Russian corporate registries, land registries, and court databases provide meaningful information, though access routes for foreign creditors are more constrained than for domestic claimants. Early-stage asset tracing — before proceedings are filed and before the debtor has notice of foreign proceedings — is materially more productive than retrospective investigation. Practitioners advising on this step will wish to consult the firm's practical guide to worldwide freezing orders and the detailed analysis of the law and practice of worldwide freezing orders in the Russian context.

The third priority is security calibration. Given the stricter proportionality approach now applied by Russian courts, the application for interim relief should be constructed around identified specific assets — real property, participatory interests in Russian entities, bank account claims — rather than as a global measure. Broad-form applications are not unavailable, but they face a higher evidentiary burden and are more frequently modified or refused at the interim stage. Counsel preparing a Russian interim measures application should be in a position to identify the specific assets sought to be frozen and to justify the measure's scope relative to the quantum of the underlying claim.

Foreign creditors who have not yet reviewed their enforcement position against these developments should be aware that Russian asset dissipation — whether through voluntary transfer, corporate restructuring, or the onset of insolvency proceedings — may occur faster than the timeline required to obtain and domesticate a foreign order. Creditors are well advised to treat their Russian enforcement plan as a live operational file, not a contingency.

To discuss your enforcement strategy in relation to Russian-situated assets, contact the team for an initial 30-minute meeting — complimentary: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

"The structural gap between a foreign freezing order and effective control over Russian-situated assets has not closed — but the procedural tools for bridging it have become more specific. A targeted, asset-by-asset approach to Russian interim relief now consistently outperforms broad-form applications." — Elizaveta Razina, Senior Lawyer, Practice Lead – IP Enforcement, Vetrov & Partners

• A practical guide to worldwide freezing orders and Russian assets
• The law and practice of worldwide freezing orders in the Russian context
• Asset tracing and recovery in Russia: an overview for foreign creditors

Q: What specifically changed in early 2026 regarding worldwide freezing orders and Russian-situated assets?

A: Russian courts have not adopted a new statute recognising foreign freezing orders in this period. What has developed is judicial practice in two respects: a somewhat more receptive approach to domestic interim measures in arbitration-related proceedings, and a stricter proportionality test applied to the scope of interim relief sought over Russian assets. The net effect is that broad-form applications face greater scrutiny, while targeted, asset-specific applications aligned with a valid arbitration agreement have a more defined — though not guaranteed — path through the Russian courts.

Q: Which types of foreign creditors are most affected by these developments?

A: Unsecured trade creditors are most exposed: they have no proprietary right to identified assets and must rely on the Russian interim measures jurisdiction, which has become more demanding. Secured creditors with pledges over specific Russian assets are less affected by the freezing order regime but must still monitor the insolvency risk to their enforcement timeline. Distressed-debt purchasers face the most compressed windows, given that by the time they acquire a claim, Russian asset movements may already be under way.

Q: What is the most practical step a foreign creditor should take immediately?

A: The most productive immediate step is to instruct Russian counsel to conduct a preliminary asset identification exercise over the debtor's Russian-situated assets — before any proceedings are filed and before the debtor has notice of enforcement activity. Simultaneously, counsel should assess whether the contractual or factual basis of the claim supports a parallel Russian interim measures application, and whether the arbitration clause — if any — permits that application to be filed in a Russian court rather than deferred to the arbitral tribunal.

Vetrov & Partners is a Russian boutique law firm established in 2009. The firm is recognised by Pravo-300 – Russia's principal legal directory – for eight consecutive years.

The firm's Asset Tracing & Recovery practice advises foreign creditors, institutional investors, and distressed-debt holders on identifying and preserving Russian-situated assets through Russian court proceedings, parallel insolvency engagement, and cross-border coordination with counsel in other jurisdictions. With over 1,000 matters handled since inception, the team provides direct partner involvement on every engagement and has particular experience in matters before the Siberian and Ural federal circuit courts.

For matters governed by foreign law or requiring local admission in another jurisdiction, we collaborate with trusted counsel in the relevant jurisdiction.

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

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.

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