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ARTICLE · 13 NOVEMBER 2026

When Frozen Assets Meet Freezing Orders: Can Sanctioned Parties Obtain Injunctions?

Mishcon de Reya LLP
Mishcon de Reya LLP
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Mishcon de Reya LLP

Mishcon de Reya LLP

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Two recent High Court decisions involving VTB Bank, a Russian bank subject to UK sanctions, examine whether freezing orders and disclosure orders constitute "funds" or "economic resources" under UK sanctions law, and explore the practical challenges sanctioned entities face when attempting to provide fortification for cross-undertakings in damages.

United KingdomLitigation, Mediation & Arbitration

In brief

  • Two recent High Court decisions involving VTB Bank, a Russian bank subject to UK sanctions, illustrate how UK sanctions can impact the ability of a designated person to obtain a worldwide freezing order ("WFO").
  • Together, the cases confirm that sanctioned litigants can access injunctions as a remedy from the English courts but will not be given any more favourable treatment than a non-sanctioned party, and the practical impact of sanctions can determine whether an otherwise properly obtained injunction survives.

Background: the underlying dispute

VTB Bank obtained a WFO against two Kazakh defendants in aid of substantive proceedings in Russia, who later challenged the order on two fronts.

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