A French court has authorized the local enforcement of Naftogaz’s $5 billion Crimea arbitration award against Russia’s Gazprom based on a decision made earlier by The Hague.
In effect, the decision by the Paris Judicial Court allowed Ukraine’s state energy giant Naftogaz to pursue Russia’s state assets in France to recoup its losses after Russia’s Gazprom seized its assets in occupied Crimea after 2014.
Naftogaz called it a “major victory in its global legal campaign to hold Russia accountable for the seizure of its Crimean assets” in a Thursday press release.
“This order by the French court enables Naftogaz to initiate enforcement proceedings on French soil,” said Roman Chumak, CEO of Naftogaz Group. “It’s another milestone in our broader legal strategy to recover damages and defend Ukraine’s interests.”
The ruling relates to a decision issued in April 2023 by an arbitral tribunal in The Hague, which found that Russia had unlawfully expropriated Naftogaz’s assets following Moscow’s 2014 occupation of Crimea.
The $5 billion award remains the largest ever issued in any investor-state arbitration involving Ukrainian claims regarding the annexation.
Naftogaz said it has already identified Russian assets in France, registering mortgages on Russian state-linked properties valued at over €120 million ($136.7 million).
The French enforcement proceedings are led by Le 16 Law, a Paris-based law firm specializing in dispute resolution, with partners Julie Spinelli and Alexandra Szekely heading the team.
Le 16 Law provided its services pro bono (for free), according to Naftogaz. The case is also supported by Naftogaz’s legal counsel, Covington & Burling.
Naftogaz is simultaneously pursuing enforcement in several national jurisdictions, including those in the UK and Finland. The company says it will continue working to identify and freeze Russian assets abroad until full compensation is secured.
A Finnish court froze Russian assets in October 2024 after recognizing the award in what Naftogaz said was the first confirmed case of asset seizure abroad related to its claims.
A UK court recognized The Hague’s decision in December 2023, but it did not enforce any asset seizures.
Legal background of Naftogaz’s Crimea case
Naftogaz initiated arbitration proceedings in October 2016 based on a bilateral investment treaty between Ukraine and Russia.
At the time of the annexation, Naftogaz was the largest natural gas operator in Crimea, with significant holdings in gas exploration, production, storage, and distribution.
In 2021, the arbitral tribunal found that it had jurisdiction to hear the case and that Russia had violated international law.
Though Moscow initially refused to participate in the process, its representatives participated when the court was expected to issue a decision, which continued through the early months of Russia’s full-scale invasion of Ukraine in 2022.
Russia has so far refused to comply with the tribunal’s final award.
The Supreme Court of the Netherlands had also recently dismissed Moscow’s appeal against the tribunal’s earlier ruling on jurisdiction and liability.