A federal judge in Washington has approved the recognition of nearly $14 million in international arbitration awards originally granted to a Russian state owned media company, ruling that US sanctions tied to election interference do not block enforcement under international law.
US District Judge Beryl A. Howell concluded that the public policy exception under the New York Convention does not prevent recognition of the awards, even though the original claimant, TV Novosti, was later sanctioned by the United States. The judge reached her decision after requesting guidance from the federal government, which ultimately declined to take a position on whether enforcement would violate US public policy.
The case centers on arbitration awards issued in February 2024 by the International Commercial Arbitration Court at the Chamber of Commerce and Industry of the Russian Federation. The rulings granted TV Novosti a total of $13.98 million in three separate decisions against Washington based T&R Production LLC, a company that had produced political and international affairs content for RT America before the business relationship deteriorated.
Shortly before US sanctions were imposed, TV Novosti transferred its full interest in the awards to Satoriagricultural Consultancy and Projects Management LLC, known as SCPM, a consultancy based in the United Arab Emirates. According to the court, the assignment agreement was signed on August 20, 2024, weeks before the sanctions took effect.
Judge Howell acknowledged the timing of the transaction raised obvious questions, noting the possibility that the sale may have anticipated future sanctions. Still, she emphasized that the New York Convention requires enforcement of arbitral awards unless a narrow exception clearly applies.
“Notwithstanding the obvious possibility that SCPM’s transactions with the original Russian claimant may have been made in anticipation of the imposition of US sanctions,” the judge wrote, “the New York Convention requires recognition of the arbitral awards,” particularly given the government’s decision not to oppose enforcement.
The court also highlighted the unusually low price paid for the assignment. SCPM acquired the awards for roughly 2 million Russian rubles, or about $20,000, a fraction of their nearly $14 million face value. Despite that disparity, the judge accepted sworn statements asserting that TV Novosti transferred all rights to the awards without any profit sharing, deferred payments or continuing obligations.
In September 2024, the United States sanctioned TV Novosti over alleged election interference, restricting transfers of US held property to the company unless authorized by the Office of Foreign Assets Control. By that point, SCPM had already taken ownership of the awards and moved to have them recognized and enforced, arguing that no current sanctions regime barred enforcement in its favor.
SCPM relied on the New York Convention, which governs the enforcement of international arbitration awards and allows refusal only in limited circumstances, including when enforcement would violate a country’s public policy. The company maintained that enforcing the awards would not benefit any sanctioned entity, since TV Novosti no longer held any interest in them.
The US Department of Justice, responding to Judge Howell’s request for input, declined to state whether confirmation of the awards would run counter to US public policy. In an amicus brief, the government noted that SCPM’s position appeared to be that the transactions fully extinguished any interest TV Novosti had in the awards or in any payments collected.
Counsel for SCPM said the ruling turned on the timing and completeness of the assignment. “The key fact is that there was a complete assignment of the arbitration awards prior to the imposition of any sanctions,” attorney Kendall Coffey said, adding that the sanctioned entity would receive no benefit from enforcement.
Representatives for T&R Production did not respond to requests for comment. The decision adds to a growing body of cases examining how US sanctions intersect with international arbitration and cross-border enforcement, especially when ownership of awards changes hands before restrictions take effect.
