1. Background: The Loan Agreement

2. Arbitration: Two Arbitral Awards

2.1. Arbitration between Creditor and Borrower

2.2. Observations regarding the arbitration between Creditor and Borrower

2.3. Arbitration between Creditor and Guarantor

2.4. Observations regarding the arbitration between Creditor and Guarantor

 

 

3. The first hearing in the St. Petersburg City Court on the matter of recognition and enforcement of the award in Russia

3.1. The parties’ positions and the Ruling of the St. Petersburg City Court

3.2. Observations regarding the Ruling of the St. Petersburg City Court

4. Rehearing of the matter in the Supreme Court of the Russian Federation

4.1. Decision of the Judicial Collegium

4.2. Observations regarding the Decision of the Judicial Collegium
5. Complaint against the decision of the Judical Collegium and Answer of the Vice Chairman of the Supreme Court
5.1.The Answer of the Vice Chairman of the Supreme Court
5.2.Observations regarding the answer of the Vice Chairman of the Supreme Court
5.3.The 1978 Decree, the “public policy” term and analysis of the Supreme Court position regarding these matters
6. Rehearing of the Case in the St. Petersburg City Court
6.1. The new Ruling
6.2. Observations regarding the new Ruling