A Kazakh court has cleared the way for Ukraine’s state energy company Naftogaz to recover $1.4 billion from Russia’s state-owned energy giant Gazprom – the first time a foreign court has formally recognized and permitted enforcement of the arbitration award on the territory of another state.
The decision adds to cases of Ukraine’s companies forcing Russia to pay for its illegal actions through international courts and instigating a pursuit of Russian assets to hold Russia accountable for war damage.
The Astana International Financial Centre Court issued its decision recognizing a Swiss arbitral ruling and granting Naftogaz permission to pursue enforcement in Kazakhstan, the company wrote on Tuesday.
“The court’s decision in Kazakhstan is another practical result in the process of recovering funds from Gazprom. We are consistently moving forward and working to enforce the arbitration award across multiple jurisdictions. I thank the Naftogaz team for this result,” the press release said, quoting Sergiy Koretskyi, CEO of Naftogaz.
The underlying dispute stems from Gazprom’s refusal to fully pay for gas transit services under the 2019 Russia-Ukraine Gas Transit Agreement, which remained in force until Jan. 1, 2025.
In May 2022, Russian occupying forces rendered the Sokhranivka entry point inoperable. Naftogaz continued transit through the Sudzha entry point but Gazprom stopped paying in full, breaching the contract.
Naftogaz initiated arbitration proceedings in Switzerland under International Chamber of Commerce rules in September 2022. In June 2025, the tribunal issued its final award, finding Gazprom fully liable and ordering repayment of the outstanding transit debt plus interest and arbitration costs. Gazprom’s appeal to the Swiss Federal Tribunal was dismissed in January 2026, formally confirming the award’s validity.
With Gazprom declining to comply voluntarily, Naftogaz launched an international asset recovery campaign spanning multiple jurisdictions. ADL Disputes and Wikborg Rein are representing Naftogaz in the Kazakh proceedings.
Previously, Ukraine’s state-owned Oschadbank registered seizure of Russian assets in France worth approximately €87 million ($99 million) as a part of an award of damages against Russia for expropriating the bank’s assets in annexed Crimea.
In 2018, the Arbitral Tribunal in Paris ruled in favor of Oschadbank in its case against the Russian Federation. After annexing Crimea in 2014, Russia illegally expropriated Oschadbank’s assets in Crimea – premises and debts from corporate debtors involved in solar energy projects.
The court decision awarded Ukraine’s bank over $1.1 billion of compensation for damages incurred due to the unlawful expropriation.
Ukraine’s lawsuits to seize Russian assets and make Russia pay for its war create a precedent for Western law, where state property of the aggressor nation is no longer immune from enforcement, Oschadbank’s supervisory board member Roza Tapanova previously told Kyiv Post.