Abstract

This paper provides a comparative study of the autonomous sanction regimes implemented by the United States (US), the European Union (EU), and the United Kingdom (UK) in response to Russia's actions in Ukraine, examining their impact on the conduct of international arbitration proceedings. The paper also considers Russia's countermeasures, particularly its strategy of granting exclusive jurisdiction to Russian courts for disputes involving sanctioned parties, even when arbitration agreements exist. While concrete cases 'in practice demonstrate that sanctions do not necessarily bring ...