Following a series of procedural developments in the second half of 2026, the position of Russian state courts on worldwide freezing orders and Russian-situated assets at the enforcement proceedings stage has shifted in ways that matter materially to foreign creditors. Russian arbitrazh courts have, over the past year, applied a notably more structured analytical framework when considering applications for interim protective measures tied to foreign-court-issued freezing orders, and when foreign creditors seek to use Russian enforcement proceedings to give practical effect to asset-restraint orders obtained abroad. For creditors tracing assets in Russia or seeking to enforce judgments and arbitral awards against Russian-situated property, understanding this updated court practice is not an optional refinement — it is the difference between securing recovery and losing it to a debtor's disposals.
The phrase "worldwide freezing order" has no direct statutory equivalent in Russian law. What Russian courts adjudicate — at the enforcement proceedings stage — is a related but technically distinct set of questions: whether to grant or maintain Russian interim measures (obespechitelnye mery) in support of foreign proceedings; whether a foreign court's asset-restraint order can serve as a factual basis for parallel Russian protective measures; and how the courts treat evidence of asset movement adduced by a creditor who holds a foreign WFO but has not yet converted it into a Russian enforcement instrument.
In the period under review, courts in the Siberian, Ural, and Central federal districts have tended to apply a more demanding evidentiary standard when considering applications for interim protective measures brought by foreign creditors in the context of ongoing enforcement proceedings. Where previously a bare reference to a foreign court's order was often treated as sufficient to establish the urgency threshold, courts have increasingly required creditors to produce documentary evidence linking Russian-situated assets specifically to the subject of the foreign order. This shift has two practical consequences.
First, the timeline for obtaining interim protection has lengthened. Applications that would previously have been resolved on a same-day or next-morning basis are now, in the prevailing practice, subject to a short contradictory procedure — typically one to three working days — in which the debtor or asset-holding third parties may file observations. For creditors whose priority concern is preventing dissipation before a hearing, this procedural window is precisely the interval in which asset movement most commonly occurs.
Second, courts have shown greater willingness to distinguish between assets that are demonstrably connected to the transaction in dispute and general property of the debtor. The practical implication is that creditors presenting Russian courts with a broadly framed WFO obtained abroad — one that sweeps across all assets of the respondent worldwide — should not assume that Russian courts will simply mirror that breadth. Russian interim measures are, in the prevailing interpretation, calibrated to the specific Russian-situated assets identified in the creditor's application, and courts have, in a number of instances in 2026, declined to extend protective measures to categories of assets not specifically itemised by the applicant.
"Creditors who rely on a foreign WFO without conducting a parallel Russian asset-tracing exercise are, in practice, operating without the protection they believe they have." — Elizaveta Razina, Senior Lawyer, Practice Lead — IP Enforcement & Asset Protection, Vetrov & Partners
If you hold a worldwide freezing order and are considering enforcement proceedings against Russian-situated assets, the procedural window for protective measures is narrow. Make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76
The practical impact of these developments is not uniform across creditor types or asset categories. Foreign trade creditors enforcing against Russian operating companies are most directly exposed. Where the debtor's Russian estate consists primarily of accounts receivable, inventory, or equipment — assets that are neither land-registered nor listed on an exchange — courts have shown the greatest inconsistency in the scope of interim measures granted. These asset classes are the hardest to itemise with the specificity that courts now appear to require, and they are also the fastest to move.
By contrast, creditors enforcing against Russian real property and registered shareholdings have found the updated framework more navigable. Both asset classes are subject to registry-based restriction mechanisms that Russian courts are accustomed to deploying. A creditor who can point to a specific registered asset — with cadastral reference or USRLE entry — and demonstrate a connection between that asset and the underlying dispute will, in the prevailing practice, obtain interim protection more reliably than a creditor seeking a broad sweep of unregistered assets.
Foreign institutional creditors and distressed debt buyers operating under English-law or New York-law instruments face an additional complication. Their WFOs are typically framed in the broad terms customary in English commercial courts. Translating that breadth into a Russian enforcement application requires specific local work: a Russian asset-tracing exercise, a creditor-side draft of the protective measures application particularising each asset, and an analysis of the connection between each identified asset and the transaction. Creditors who have not done this work before presenting their application to a Russian court are, in practice, presenting an incomplete case.
The EAEU and CIS dimensions also warrant attention. For creditors who have obtained WFOs covering assets in multiple post-Soviet jurisdictions, Russian courts have not treated the existence of parallel proceedings or orders in EAEU member states as a basis for widening the scope of Russian protective measures. Each jurisdiction is assessed independently, and a Kazakh or Belarusian court's order does not, in the Russian courts' current approach, serve as a foundation for Russian interim relief.
For foreign creditors who need to identify and protect Russian-situated assets before enforcement proceedings advance, an early-stage asset-tracing instruction is the practical starting point. Discuss your matter in confidence: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76
The practical guidance that follows from the 2026 developments is structured around timing and specificity — the two variables that courts have most consistently flagged as dispositive.
On timing: interim protective measures applications should, where possible, be filed simultaneously with or immediately following the initiation of Russian enforcement proceedings, not after. Creditors who allow a gap between the initiation of enforcement and the application for protective measures give the debtor an unprotected window. In the prevailing practice, courts have treated a creditor's delay in applying for interim protection as a factor weighing against urgency — which is, perversely, the very condition the court is being asked to find.
On specificity: each Russian-situated asset to be covered by the protective measures application should be individually identified before the application is filed. This requires a prior asset-tracing exercise using Russian registry data — including the Unified State Register of Real Estate (USRRE), the corporate registry (USRLE), and, where applicable, records of vehicle and equipment registration. Creditors holding a broadly framed English or New York WFO should treat that order as the starting point for a Russian asset investigation, not as a substitute for it.
On the foreign WFO itself: the order should be translated, notarised, and apostilled before being presented to a Russian court. Courts have, in the period under review, declined to consider foreign-language materials presented without proper legalisation, even where the content of the order was substantively relevant. The procedural hurdle is avoidable with preparation.
On parallel proceedings: where a creditor holds both a foreign WFO and is pursuing Russian enforcement proceedings, the two procedural tracks should be coordinated. In particular, any asset disposals or third-party transactions that the creditor becomes aware of should be reported to both the foreign court (to preserve the WFO's contempt mechanism) and the Russian enforcement proceedings, where a separate application to extend or adjust protective measures may be warranted.
For creditors instructing local Russian counsel at this stage, the practical priority is ensuring that the Russian application is drafted to the standard that the updated court practice now requires — not to the standard that was sufficient in earlier years.
The Asset Tracing & Recovery practice at Vetrov & Partners advises foreign creditors at each stage of this process, from initial Russian asset investigation through to the drafting and filing of protective measures applications in Russian arbitrazh courts. For guidance on the law and practice of worldwide freezing orders in the Russian context, or on the practical steps involved in obtaining protective measures, see the linked resources from the firm's Insights library.
Q: What specifically changed in Russian court practice on worldwide freezing orders at the enforcement stage in 2026?
A: The most significant shift is evidentiary and procedural. Russian arbitrazh courts, in the period under review, have moved towards a more demanding standard for interim protective measures applications brought by foreign creditors in the context of WFO-related enforcement. Creditors are now expected to identify specific Russian-situated assets — by registry reference where possible — rather than relying on the breadth of a foreign court's order. Courts have also, in a number of instances, introduced a short contradictory window before deciding on interim measures, which creates a narrow but real risk of asset dissipation during the hearing process. Creditors who prepared their applications to the standard applicable in earlier years should have their Russian enforcement strategy reviewed.
Q: Which foreign creditors are most affected by these developments, and in what way?
A: Foreign trade creditors and distressed debt buyers enforcing against Russian operating companies are most directly affected, particularly where the debtor's estate consists of unregistered or mobile assets such as accounts receivable, inventory, or equipment. Creditors with broadly framed English or New York WFOs face an additional challenge: Russian courts do not mirror the breadth of a foreign order and require a Russia-specific asset particularisation. Creditors enforcing against registered assets — real estate, shareholdings — are less exposed, as the registry-based restriction mechanism is well established. Creditors operating through EAEU or CIS co-proceedings should note that parallel orders from other post-Soviet jurisdictions do not, in the current practice, expand the scope of Russian interim protection.
Q: What should a foreign creditor holding a worldwide freezing order do now to protect Russian-situated assets at the enforcement stage?
A: Three steps are operationally critical. First, conduct a Russian asset-tracing exercise before filing any protective measures application — identify each relevant asset by registry reference. Second, file the interim protection application at the same time as, or immediately following, the initiation of Russian enforcement proceedings; delay is treated by courts as evidence against urgency. Third, ensure the foreign WFO is properly translated, notarised, and apostilled before presentation to a Russian court. Beyond these immediate steps, creditors should coordinate their foreign and Russian procedural tracks so that any asset movement is reported and addressed in both forums simultaneously.
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, and is listed as a trusted adviser by the German Consulate General in Novosibirsk.
The firm's Asset Tracing & Recovery practice advises foreign creditors — including trade creditors, institutional investors, and distressed debt buyers — on Russian-law enforcement proceedings, interim protective measures, and cross-border asset recovery. With over 1,000 matters handled since inception, the team combines direct knowledge of Russian arbitrazh court practice across the Siberian and Ural federal districts with partner-level involvement on every engagement.
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 & Asset Protection, Vetrov & Partners vetrovpartners.com/razina/