EU 21st Package — Anti-Suit Injunction Mechanism Reinforced and Russian Judgment Non-Recognition Established

The EU's 21st Russia sanctions package contains two provisions directly relevant to dispute resolution and litigation practice: reinforcement of the anti-suit injunction mechanism against enforcement in non-EU countries of sanctions-related Russian judgments, and a new framework providing that Russian court decisions in sanctions-affected disputes will not be recognised in EU jurisdictions. Together, these provisions reflect the growing legal architecture of the Russia-Ukraine conflict's commercial and contractual fallout — a second-order legal conflict running alongside the military conflict and generating complex questions about contract frustration, force majeure, arbitration clause enforcement, and asset recovery that will occupy transactional and dispute practices for years. For litigation and arbitration teams, the reinforced anti-suit injunction mechanism means EU counterparties to Russia-related disputes have stronger legal tools to resist enforcement of Russian judgments in EU member states, and the non-recognition framework creates a defence against any attempt to use Russian court decisions to affect EU-based assets or obligations. The extended exit and wind-down derogations — available for firms divesting from Russia or winding down operations until December 31, 2027 — preserve professional services authorisations for legal work necessary to complete those transactions and should be documented carefully by firms assisting clients in Russia exit transactions.