Parallel Proceedings Involving Russia: A Practical Guide for International Counsel

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Practice Analysis

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By Vitaliy Vetrov

May 2026

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When a commercial dispute has a Russian element — a Russian-law governed contract, a Russian-domiciled defendant, assets in Russia — the foreign counsel managing the principal arbitration or litigation will at some point need to consider whether parallel proceedings in Russia are necessary, and if so, what shape they should take. This guide addresses the most common parallel proceedings scenarios that arise in cross-border mandates and the practical questions that foreign counsel should ask before instructing Russian local counsel.

Why Parallel Russian Proceedings Arise

Foreign counsel encounter three recurring scenarios in which Russian proceedings become necessary alongside the main international proceeding.

The most common scenario. An ICC, LCIA, SIAC, or HKIAC award has been obtained. The respondent is a Russian entity or has assets in Russia. Recognition proceedings in the Russian arbitrazh court are necessary before the award can be enforced against Russian assets. This is a standalone Russian proceeding — it is not an appeal of the award but an application to give it legal effect in Russia.

Enforcement of an arbitral award

Russian witnesses or Russian-held documents may be material to an international arbitration or foreign court proceeding. Obtaining witness statements from Russian-domiciled individuals and managing document requests directed at Russian entities requires specific procedural management in Russia, including — in some cases — applications under the Hague Convention on the Taking of Evidence Abroad.

Collection of evidence for use in the international proceeding

Where the respondent has filed or threatened to file an application in the Russian courts — seeking a Russian judgment that might complicate the international proceeding — the claimant may need to file protective proceedings in Russia to preserve its position. This scenario is less common than the first two, but arises in disputes involving parallel jurisdiction clauses or where the respondent seeks to exploit inconsistencies between the Russian and international proceedings.

Defensive or protective proceedings

Coordinating the Russian Track

The principal question for foreign counsel in any parallel proceedings scenario is how the Russian track should be structured relative to the international proceeding. Three aspects of coordination are typically relevant:

The Russian proceeding should be commenced at the point that produces the maximum tactical benefit. For enforcement proceedings, this means assessing whether interim relief can be obtained in Russia before the award debtor is served with the recognition application — and calibrating this to the timelines of any enforcement proceedings in other jurisdictions. For evidence collection, the Russian process should be timed to produce the evidence within the window required by the arbitral tribunal or foreign court.

Timing

Evidence obtained in Russian proceedings — including documents produced in response to court orders and witness statements taken under Russian procedure — may be introduced into the international proceeding. The admissibility of Russian-procedure evidence in international arbitrations is well-established; the practical question is whether the format and authentication of the evidence meets the arbitral tribunal's requirements. Russian local counsel should be briefed on those requirements at the outset.

Information sharing

The principal risk in parallel proceedings is that the Russian court and the international tribunal reach inconsistent factual or legal conclusions. This risk is managed by ensuring that positions taken in the Russian proceeding are consistent with the strategy in the international proceeding, and by keeping the overall strategy under the direction of the lead counsel in the principal proceeding.

Risk of inconsistent outcomes

Practical Points for Briefing Russian Counsel

The efficiency of Russian parallel proceedings depends significantly on the quality of the instruction from the outset. Based on our experience acting as Russian counsel in parallel proceedings managed by international teams, the following points make a material difference to outcomes.

Russian counsel who understand the full factual and legal narrative of the international proceeding are better placed to identify risks in the Russian track and to draft the Russian submissions in a way that is consistent with the international strategy. Providing only a summary of the case — or providing information in stages — leads to avoidable gaps.

Provide the full arbitral record from the start

Russian proceedings have their own procedural timetable. Foreign counsel should specify what they need to know, in what format, and with what frequency. A communication protocol agreed at the outset — covering the format of court orders, the timing of status reports, and the escalation procedure for urgent developments — avoids delays in information flow at critical moments.

Set clear reporting requirements

Documents produced in the Russian proceedings may need to be introduced into the international proceeding. Certified English translations should be commissioned as part of the standard workflow, not as an afterthought when the arbitral tribunal requests them.

Anticipate translation requirements early

In a parallel proceedings structure, Russian counsel typically manage the Russian procedural track independently — appearing at hearings, filing submissions, and responding to court orders — but within a strategy set by the lead counsel. The boundary between what Russian counsel can decide autonomously and what requires approval from the international team should be established explicitly, because Russian procedural timelines sometimes require responses within hours rather than days.

Be precise about what Russian counsel is, and is not, authorised to decide

The Evidence Collection Track

For international arbitrations requiring evidence from Russia, the two primary routes are the formal Hague Convention route and the informal witness statement route.

The formal Hague Convention route — a request issued through the Russian Ministry of Justice — is procedurally sound but slow. The typical timeline from issue of the request to execution is six to twelve months. For arbitrations with a fixed evidentiary cutoff, this route is rarely viable.

The informal route — obtaining voluntary witness statements from Russian-domiciled witnesses without a court order — is the approach adopted in most international arbitrations involving Russia. Russian witnesses can provide voluntary statements that comply with the formal requirements of the arbitral tribunal (for example, statements in the form required under IBA Rules on the Taking of Evidence) without the formal process. The practical constraints are different: the witness must be willing to participate voluntarily, and the statement must be authenticated in a form that the arbitral tribunal accepts.

In our experience, the key determinant of success in Russian evidence collection for international proceedings is the speed and quality of the initial approach to the witness — before the opposing party makes contact. Early instruction of Russian counsel on the evidence collection track is therefore as important as early instruction on the enforcement track.

Vitaliy Vetrov

Is Managing Partner of Vetrov & Partners. He acts as Russian counsel in parallel proceedings arising from international arbitrations, coordinating the Russian procedural track with international litigation teams at international law firms.

This article reflects the law and practice as of May 2026.

Related reading:

Enforcing Foreign Arbitral Awards in Russia: The Procedural Map

Interim Relief Before a Russian Court

Cross-border Disputes & Arbitration — Practice Page