Taking the assets, not just winning the award — sovereign immunity from execution across jurisdictions
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The single distinction that governs everything below
An ICSID award creditor can almost always get the award recognised abroad — turned into a domestic judgment. Actually executing it — seizing or freezing a State's property to satisfy the debt — is a separate question, governed by each country's own law of immunity from execution, and it succeeds only rarely.
By acceding to the ICSID Convention a State agrees that every other Contracting State will recognise and enforce the award as if it were a final judgment of its own courts. This waives immunity from adjudication. Every apex court outside the EU has so held.
Article 55 expressly preserves the domestic law of immunity from execution. Recognition hands you a judgment, not money. Whether you can then take assets depends entirely on the enforcing State's own immunity rules.
Across every jurisdiction the same line runs: only commercial (iure gestionis) property can be reached. Property used for sovereign purposes — embassies, central-bank reserves, military assets, diplomatic premises — is immune.
Actual seizures satisfying an award are rare and slow. The richest examples are freezing and attachment (often later reduced or lifted); the clearest paid-out cases took a decade or more and were assembled asset by asset.
Two refinements that recur throughout
First, the preservation of execution immunity in Article 55 was, on the record of the ICSID Convention’s drafting, largely unconsidered: as the standard commentary records, “abandonment of immunity of execution was mentioned by only one representative and his statement found no echo whatsoever.” The gap that defeats most creditors was a silence, not a deliberate bargain. Second, the fora that permit execution against commercial property do not draw the line in the same place: some — England among them — allow execution against any property in commercial use, while others permit it only against property used for the very commercial activity on which the claim is based. A creditor must show not merely that an asset is commercial, but that it is commercial in the sense the particular forum requires.
Execution only against commercial property; central-bank and military assets carved back out
The Foreign Sovereign Immunities Act sets the baseline: a State's US property is immune from attachment and execution, subject to narrow exceptions.
The statutory scheme
Mobil Cerro Negro Ltd v Bolivarian Republic of Venezuela, 863 F.3d 96 (2d Cir. 2017).
That recognition of an ICSID award is available under the FSIA is settled: the Second Circuit confirmed that actions to enforce ICSID awards fall within the FSIA’s specific exceptions to immunity under §§ 1605(a)(1) and (6). That is the recognition side of the ledger, and it is not controversial. The difficulty lies downstream, at execution.
Liberian Eastern Timber Corp v Government of the Republic of Liberia, 650 F. Supp. 73 (S.D.N.Y. 1986); 659 F. Supp. 606 (D.D.C. 1987).
LETCO held an ICSID award of $8,793,280; an ex parte judgment was entered for $9,076,857.25 including interest, and a Writ of Execution was issued to the US Marshal on 25 September 1986. This is the clearest early example of an ICSID creditor actually reaching for a State's US property.
It also shows exactly where the wall stands. The S.D.N.Y. decision concerned executions levied on Liberian ship-registry fees and tonnage taxes; the court held these were tax revenues serving governmental functions, not property “used for a commercial activity,” and vacated the executions — while expressly leaving LETCO free to execute against genuinely commercial property under § 1610. Weinfeld J confirmed the Article 54/55 split: Article 55 “only applies to the execution of a judgment once it is entered.”
In the parallel D.C. proceeding the writs had seized embassy bank accounts at Riggs and First American; those were held immune under the Vienna Convention and, as to the central-bank account, § 1611(b)(1). (The 659 F. Supp. 606 embassy/central-bank holding is verified from law-report databases; the full opinion has not been read line by line.)
Crystallex Int’l Corp v Bolivarian Republic of Venezuela, 333 F. Supp. 3d 380 (D. Del. 2018), aff’d 932 F.3d 126 (3d Cir. 2019), cert. denied.
The leading modern execution success, and the closest to this project’s subject. Crystallex held an ICSID award of US$1.2 billion for the expropriation of a gold project, confirmed as a US$1.4 billion judgment. Unable to find Venezuelan commercial property in the United States it could lawfully seize, it registered the judgment in Delaware and moved to attach the shares of PDV Holding — the Delaware parent, through PDVSA, of CITGO — on the footing that the State oil company PDVSA was the alter ego of Venezuela.
The District Court agreed. Applying the Bancec presumption of separate juridical status and finding it rebutted by Venezuela’s extensive control over PDVSA, it held PDVSA to be the Republic’s alter ego, so that its PDVH shares were not immune and could be attached. A writ of attachment issued and a court-supervised sale process was established, ranking a queue of Venezuela’s creditors behind Crystallex.
Two features make it central: it is an ICSID award realised against a State oil company’s foreign shares through alter-ego attachment — the very manoeuvre States structure their holdings to resist — and it has drawn a queue of other award creditors onto the same auction (ConocoPhillips, ~US$8.7bn; Rusoro; Gold Reserve). The Delaware court entered a final sale order on 1 December 2025, approving Elliott/Amber Energy’s ~US$5.9bn bid for the PDV Holding shares. One honest qualification: closing is stayed pending OFAC licensing (and any Third Circuit appeal), so as of October 2026 the sale is approved but not yet closed and no cash has been disbursed — the breakthrough is the attachment, the alter-ego finding and now an approved buyer and price; the cash still awaits sanctions clearance. Justia (3d Cir.).
Recognition settled by UKSC 9; execution turns on s.13(3) consent or s.13(4) commercial use
Recognition is now conclusively settled for the creditor. Execution runs down two routes — the State's written consent, or the narrow commercial-use exception — with central-bank property absolutely protected.
The statutory scheme
Kingdom of Spain v Infrastructure Services Luxembourg S.à.r.l.; Republic of Zimbabwe v Border Timbers Ltd [2026] UKSC 9 (Lord Lloyd-Jones and Lady Simler, unanimous), 4 March 2026.
The Supreme Court held that Article 54(1) of the ICSID Convention is a clear and unequivocal submission to the adjudicative jurisdiction of the English courts under s.2(2) SIA 1978. The test at [69]: a treaty waiver requires “a clear and unequivocal expression of the state's consent” but “does not require explicit words such as waiver or submission.” Lord Goff's narrower view in Pinochet (No 3) was rejected.
But the Court was careful at [21]: “We are concerned ... with immunity from adjudicative jurisdiction only. We are not concerned with immunity from execution.” Zimbabwe's reserved non-immunity defences were remitted to the Commercial Court. This is the recognition victory — it does not, by itself, take a single asset.
General Dynamics United Kingdom Ltd v State of Libya [2025] EWCA Civ 134 (Phillips, Lewison, Zacaroli LJJ, unanimous).
An ICC award (Geneva seat, Swiss-law contract) of £16,114,120.62, recognised in England under s.101 Arbitration Act 1996. The creditor obtained an interim charging order over a Libyan-owned property in London; Libya sought to discharge it under s.13(2)(b).
The Court of Appeal held that the arbitration clause — “the decision of the arbitration panel shall be final, binding and wholly enforceable” — amounted to Libya's written consent to execution under s.13(3). No heightened “clear words” gloss: the task is to construe the words under the governing (Swiss) law. The charging order stood.
This is the clean UK execution win — but on the consent route, not commercial use, and on an ICC award. The reasoning transfers to ICSID, though ICSID awards rarely contain such an express “wholly enforceable” consent, so the s.13(4) commercial-use route is the likelier — and narrower — ICSID path.
AIG Capital Partners Inc v Republic of Kazakhstan (National Bank of Kazakhstan intervening) [2005] EWHC 2239 (Comm), [2006] 1 WLR 1420 (Aikens J).
An ICSID award of US$9,951,709 plus interest, registered under the 1966 Act. The creditor sought final third-party debt and charging orders over cash and securities held in London by a custodian under a Global Custody Agreement with the National Bank of Kazakhstan. Held: the accounts were “property of a State's central bank” within s.14(4) and therefore immune — and that immunity is compatible with Article 6 ECHR. The clean example of a failed execution on central-bank assets. (Kazakhstan reportedly paid some years later.)
SerVaas Incorporated v Rafidain Bank [2012] UKSC 40.
The Supreme Court’s first look at immunity from execution since Alcom. SerVaas sought a third-party debt order over dividends payable to Iraq in a scheme of arrangement, arguing the underlying debts’ commercial origin made the property commercial. Held, unanimously: the origin of property is irrelevant — s.13(4) turns on present or intended use. As the dividends were bound for the Development Fund for Iraq (sovereign purposes) they were immune, and the ambassador’s certificate (s.13(5)) raised a presumption SerVaas could not rebut. National Archives.
Orascom Telecom Holding SAE v Republic of Chad [2008] EWHC 1841 (Comm).
The counter-example, and the nearest an award creditor has come to executing against commercial State property in England. Orascom held an ICC award against Chad and sought a third-party debt order over Chad’s Citibank accounts in London. Burton J held the “Borrower’s Account” — set up under a World Bank revenue-management programme to receive oil-pipeline proceeds — was in commercial use within s.13(4), and therefore not immune. The rare reported case in which s.13(4) defeated a State’s immunity claim; but it turned on the account’s evidenced commercial character, and Chad led little evidence. BAILII.
The narrow honest point on the UK: recognition is settled (UKSC 9), the consent route can work (General Dynamics), and the commercial-use route is read narrowly — Alcom Ltd v Republic of Colombia [1984] AC 580 held a general embassy account indivisible and immune unless earmarked solely for commercial use. There is still no reported case of an ICSID creditor levying on UK commercial State assets and keeping the proceeds.
Where assets have most often actually been attached — and where the rules keep changing
France is where sovereign assets have most frequently been attached, and where the doctrine on waiver is most developed. It is also where the legislature has repeatedly stepped in to protect States, so the governing test must always be pinned to its date.
Cour de cassation, 1re civ., 6 February 2007, linked pourvois n° 04-13.107 (Walker International Holdings) and n° 04-13.108 / 04-16.889 (Connecticut Bank of Commerce / AF-CAP). CA Paris, 3 July 2003.
Creditors of the Republic of Congo (enforcing a London High Court judgment given exequatur in France, and an arbitral award) levied saisies-attributions on 24 October 2001 over the accounts of the Congolese State oil company SNPC at BNP Paribas and Société Générale.
The live question was the théorie de l'émanation: whether SNPC — a separate legal person — was an emanation of the Congo such that its assets answered for the State's debt. The Paris Court of Appeal held it was, and the seizures valid. A concrete example of a State entity's commercial bank accounts being reached in a third country. (The Cassation reasoning is verified on Légifrance; the precise operative disposition of each pourvoi should be read in the full arrêt before client use.)
Cass. 1re civ., 13 May 2015, n° 13-17.751; chronology confirmed by Cass. 3 February 2021, n° 19-10.669. (ICC award — the immunity analysis is identical to ICSID.)
On an ICC award against Congo, Commisimpex pursued bank accounts, immovable property, diplomatic property, tax receivables and an aeroplane. The courts treated the 1993 waiver letter as “express,” valid for most State property — but held diplomatic property required a waiver both “express” and “special.” Enforcement thus succeeded except as to diplomatic assets.
The rule kept moving. The express-and-special requirement was set on 28 September 2011, reiterated 28 March 2013, abandoned on 13 May 2015, then reimposed by the Loi Sapin II (9 December 2016) — which also now requires prior court authorisation for any seizure of State property — and applied again in 2018. Any citation must name the date, because the governing test changed at least four times.
Creighton Ltd v Government of Qatar, Cour de cassation, 1re civ., 6 July 2000, n° 98-19.068.
Creighton held ICC awards against Qatar and attached Qatari assets in France; the lower courts ordered the seizures lifted, reasoning that agreeing to arbitrate did not presume a waiver of execution immunity, which is distinct from immunity from jurisdiction. The Cour de cassation reversed: the undertaking a State gives, by signing an arbitration agreement subject to the ICC Rules, to carry out the resulting award — then Art 24, now Art 34.6 — itself implies a waiver of immunity from execution, not merely from jurisdiction.
This is the French counterpart to the General Dynamics consent route, and the two connect: the English Court of Appeal cited Creighton on the ICC Rules’ duty to carry out an award. But it must be read with its qualifications — it sat in tension with the earlier EURODIF v Iran (consent to ICC arbitration held not to waive execution immunity), and the Cour de cassation later tightened the test so that even an express waiver does not reach protected assets (see NML below).
Paris Cour d’appel, 10 August 2000; (2001) Rev Arb 114. (ICC award — immunity analysis identical to ICSID.)
Compagnie NOGA, holding an ICC award against Russia, obtained exequatur in France and seized bank accounts of the Russian embassy, its commercial delegation and its UNESCO delegation. Notwithstanding express contractual waivers of execution immunity, the Paris Court of Appeal held the accounts protected: diplomatic immunity is governed by the distinct regime of the 1961 Vienna Convention (Arts 22(3), 25), and a general waiver does not extend to diplomatic assets. Attempts to seize a Russian ship at Brest and military aircraft at an air show also failed. The pairing with Creighton is the lesson: agreeing to ICC arbitration may waive execution immunity in principle, but the waiver still cannot reach property the Vienna Convention protects.
Cass. 1re civ., 28 September 2011 (n° 09-72.057) and 28 March 2013 (n° 10-25.938, 11-10.450, 11-13.323). Bonds, not an award — but the immunity-from-execution doctrine is the same.
A general contractual waiver was held insufficient to reach diplomatic assets or sovereign-purpose tax and social-security receivables: the waiver must be “express and special,” naming the assets or category. NML held a bargained-for waiver of execution immunity — stronger than anything ICSID confers — and still could not reach those assets. An a fortiori caution.
Consequential attachments against sovereigns — from Euroclear to Eurocontrol
Belgium has been the situs of some of the most consequential attachments against sovereigns — each turning on the interception of funds passing through an intermediary established there. The classic pair are Elliott v Peru (Euroclear) and Stati v Kazakhstan (a custodian bank); and the same logic is now being run against Spain, through the en-route charges that Eurocontrol remits to ENAIRE.
Elliott Associates LP v Republic of Peru, Court of Appeal of Brussels, 8th Ch., 26 September 2000 (not officially reported).
The seminal demonstration that a determined creditor can force a recalcitrant State to pay. Holding a US money judgment on defaulted Peruvian debt, Elliott attacked the payment channel: it obtained a Brussels order barring Chase Manhattan and Euroclear from paying interest on Peru’s Brady bonds, on a pari passu argument. With the channel frozen, Peru faced fresh default on the whole US$3.8bn programme and settled within days for ~US$58.45m.
It concerns sovereign bonds, not an award, but it is the seminal illustration of the principle that governs award execution too: value is realised by finding a commercial choke-point the State cannot afford to see frozen, not by meeting immunity head-on. Belgium later legislated to immunise Euroclear-held sums — a successful method provoking a protective response. BIS Papers 72.
ECT award (SCC, ~US$506m). Multi-jurisdiction enforcement; the English referral judgment is National Bank of Kazakhstan v The Bank of New York Mellon [2020] EWHC 916 (Comm).
Belgium, October 2017: an attachment/garnishment order over securities and cash held by BNY Mellon — assets forming part of Kazakhstan's National Fund, held at BNYM's London branch under an English-law custody agreement with the National Bank. BNYM “could not fully exclude” that Kazakhstan had claims on it and froze about US$22.6 billion, later reduced to the award value of US$530m. The Belgian court referred the “attachable obligation” question to the English court to decide under English law.
Netherlands: the Amsterdam District Court upheld an attachment of Kazakhstan's ~US$5.2bn stake in the Kashagan oilfield vehicle (held via the sovereign wealth fund). Further attachments followed in Sweden, Luxembourg and Italy. The largest freeze of sovereign assets on an investment award — though a freeze via a third-party custodian is not the same as a completed handover, and the litigation was long and contested.
Intra-EU ECT/ICSID renewable awards against Spain, enforced through Belgian conservatory attachments (saisie-arrêt conservatoire). Reported by Spanish and international press, January 2026; not yet verified against the Belgian court files.
The same choke-point logic as Elliott v Peru, turned on a State that will not pay its renewable-energy awards. Eurocontrol — the European air-navigation organisation, headquartered in Brussels — collects en-route charges from airlines and remits them to each State's air-navigation service provider. For Spain that provider is ENAIRE. Award creditors have obtained Belgian orders garnishing those charges in Eurocontrol's hands before they reach ENAIRE. Spanish and international reporting put the aggregate frozen at roughly €482 million across some two dozen investors as of January 2026; Eurus Energy (a Toyota subsidiary) is reported to have obtained an attachment of about €207m in July 2025, and OperaFund is among the creditors said to be using the route.
Three hurdles stand between the freeze and any money. First, these are conservatory (security) measures, not completed execution: the money is frozen, not handed over, and a conservatory attachment is granted on a prima facie claim without the court first validating the award — so when Spain contests, the Belgian court must confront the Achmea/Komstroy objection at the exequatur stage, the very question on which Luxembourg refused Micula. The route defers the EU-law problem; it does not escape it. Second, Eurocontrol's own privileges and immunities as an international organisation: funds in its hands are not simply Spain's bank balance, and Eurocontrol's status as garnishee is itself contestable. Third, the “attachable obligation” question that decided Stati v Kazakhstan at BNY Mellon: are the route charges owed to Spain, or to ENAIRE as a juridically separate entity? If the latter, the separate-entity / alter-ego analysis that runs through this whole note applies, and the attachment reaches the wrong debtor. A parallel conservatory seizure of a Spanish cultural building in Utrecht (Spain notified 20 April 2026) was obtained by an award assignee and then lifted by the Dutch court — the same conservatory-not-final pattern. As a matter of pressure applied, though, the Eurocontrol route is the furthest the campaign against Spain has reached. verify against Belgian/Dutch court records
The clearest instance of a creditor actually being paid
The clearest instance of a creditor actually being paid out of seized sovereign property — a single long-running campaign, the realisation occurring in Germany, the most-cited ruling being the Swedish Supreme Court’s.
BIT award (SCC, 7 July 1998). Enforced in Germany and Sweden over more than a decade. Swedish Supreme Court, NJA 2011 s. 475, Case No Ö 170-10, 1 July 2011.
Germany: Sedelmayer discovered a Cologne apartment complex (once used by the KGB) owned by the Russian Federation. In 2006 a Cologne court ordered its judicial sale; from 2005 he received rents via a court-appointed sequester; by December 2008 public auctions went ahead and Russia was forced to bid for its own buildings. He eventually collected around US$6.8m. Instructive failures alongside: attempts to seize Lufthansa overflight fees and Russian VAT refunds were rejected as immune — only the commercially-let property could be reached.
Sweden: the Supreme Court held a Stockholm trade-mission building not immune because it was mixed-use — let as residence to around sixty people, none notified as diplomats, plus companies using it as their business address. The building was later ordered sold at auction. A rare case of a court allowing execution against a partly-official building, as to its commercial portion.
Two decisions that round out the survey — each defeating execution
Two further decisions round out the survey — one confirming the reach of sovereign-purpose immunity, the other of absolute immunity — each defeating execution.
Sistem Mühendislik v Kyrgyz Republic, Swiss Federal Supreme Court, Decision 5A_681/2011, 23 November 2011.
One of the few decisions on executing an ICSID award directly. Holding a 2009 ICSID award, Sistem attached airspace-navigation charges collected on the Kyrgyz Republic’s behalf by IATA in Geneva. The Debt Collection Office refused; the Federal Supreme Court upheld the refusal: under Article 92 of the Swiss Debt Enforcement and Bankruptcy Act, assets allocated to the exercise of sovereign authority — here, surveillance of national airspace — are immune. Consistent with Article 55, execution immunity is decided under the forum’s domestic law, which additionally requires a sufficient connection to Switzerland. analysis.
FG Hemisphere Associates LLC v Democratic Republic of the Congo [2010] 2 HKLRD 66 (CA); Hong Kong Court of Final Appeal, 2011.
An attempt to attach mining entry fees owed to the DRC failed when, after Beijing's intervention, Hong Kong applied the PRC doctrine of absolute sovereign immunity — no commercial exception at all. A reminder that the enforcing forum's own immunity doctrine can defeat execution entirely, whatever the award says.
Yes in principle; only against commercial property; and the trend is towards more protection
An ICSID creditor can execute against a State abroad — never against embassy, central-bank, military or diplomatic assets, but by one of four routes: the commercial-use exception, the State’s written consent to execution, alter-ego attachment of a controlled State entity, and the freezing of a commercial payment channel the State cannot afford to lose.
The four routes — each with a real precedent
General Dynamics (UK); Creighton (France) — an arbitration agreement construed as written consent to execution.
Crystallex (US) — PDVSA pierced as Venezuela’s alter ego; its CITGO-parent shares attached.
Elliott v Peru (Belgium) — a Euroclear freeze that forced settlement within days.
Orascom (UK); SNPC (France) — property the State itself puts to commercial use.
Reachable asset classes within those routes
SNPC v Walker (France) — accounts of the State oil company attached as an emanation of the State.
Sedelmayer (Germany and Sweden) — buildings let commercially, sold at auction to pay the award.
Commisimpex (France) — tax receivable attached at the French registered office of the debtor.
Stati v Kazakhstan (Belgium, Netherlands) — National Fund assets frozen at a custodian bank.
Elliott v Peru (a payment freeze that forced settlement in days) and Sedelmayer (Cologne buildings sold at auction). Crystallex is the largest modern breakthrough — assets attached and a sale ordered — though the cash awaits sanctions clearance.
LETCO (registry taxes, embassy accounts), AIG (Kazakh central bank in London), Sistem (Kyrgyz airspace fees, sovereign-purpose), FG Hemisphere (Hong Kong absolute immunity), and the diplomatic-property limb of Commisimpex.
Where a creditor actually seized, froze or realised value from State property
The cases in which execution actually reached State property, distinguished by outcome. Payment realised means cash was actually recovered; assets reached means property was attached or execution permitted, though not necessarily yet turned into cash; assets frozen means property was secured pending resolution. Several rest on BIT, ECT or ICC awards rather than ICSID; the immunity-from-execution analysis is common to all.
| Case | Forum | Outcome | What was reached | Source |
|---|---|---|---|---|
| Elliott Associates LP v Peru | Belgium | Payment realised | Brussels court froze Peru’s Brady-bond interest passing through Euroclear; Peru settled within days for ~US$58.45m | BIS Papers 72 |
| Sedelmayer v Russian Federation | Germany | Payment realised | Cologne apartment complex (commercially let) sold at judicial auction; ~US$6.8m recovered over a decade | ECtHR, Sedelmayer v Germany |
| Crystallex Int’l Corp v Venezuela | United States | Assets reached; sale ordered (cash pending) | PDVSA held Venezuela’s alter ego; its PDV Holding / CITGO shares attached and a court-supervised sale ordered (held up by OFAC sanctions licensing) | Justia (3d Cir. 2019) |
| Sedelmayer v Russian Federation | Sweden | Execution permitted | Swedish Supreme Court held a mixed-use Stockholm trade-mission building not immune as to its commercial portion; execution against rents allowed | Jus Mundi (Eng. trans.) |
| SNPC v Walker / Connecticut Bank | France | Accounts attached | French bank accounts of the Congolese State oil company (SNPC) attached as an emanation of the State (BNP Paribas; Société Générale) | Légifrance |
| Commisimpex v Congo | France | Enforcement (except diplomatic) | Bank accounts, real estate, tax receivables and an aircraft reached under an express waiver; diplomatic property alone held immune | Légifrance |
| General Dynamics UK Ltd v Libya | United Kingdom | Charging order upheld | Interim charging order over a Libyan-owned London property upheld, the arbitration clause being written consent to execution under SIA s.13(3) | BAILII |
| Orascom Telecom v Chad | United Kingdom | Debt order (not immune) | Chad’s Citibank “Borrower’s Account” held in commercial use under SIA s.13(4), so not immune — third-party debt order available | BAILII |
| Creighton Ltd v Qatar | France | Waiver of execution immunity found | Cour de cassation held that agreeing to ICC arbitration itself waives immunity from execution, reversing the release of the seizures | Jus Mundi (arrêt) |
| Stati v Kazakhstan | Belgium | Assets frozen (~US$22.6bn → ~US$530m) | Belgian attachment froze National Fund cash / securities at BNY Mellon; the largest freeze on an investment award, though a freeze is not a payment | BAILII (NBK v BNYM) |
What has been checked against the court's own text, and what still rests on secondary sources
Primary-verified (court's own text read)
| Authority | Citation | Source |
|---|---|---|
| Mobil Cerro Negro v Venezuela | 863 F.3d 96 (2d Cir. 2017) | CourtListener |
| Crystallex Int’l Corp v Venezuela | 333 F. Supp. 3d 380 (D. Del. 2018); 932 F.3d 126 (3d Cir. 2019) | Justia (3d Cir.) |
| LETCO v Liberia | 650 F. Supp. 73 (S.D.N.Y. 1986) | Justia |
| AIG v Kazakhstan | [2005] EWHC 2239 (Comm) | BAILII |
| Spain / Zimbabwe v ISL / Border Timbers | [2026] UKSC 9 | National Archives |
| General Dynamics v Libya | [2025] EWCA Civ 134 | BAILII |
| SerVaas v Rafidain Bank | [2012] UKSC 40 | National Archives |
| Orascom Telecom v Chad | [2008] EWHC 1841 (Comm) | BAILII |
| Sedelmayer v Russia (Sweden) | NJA 2011 s. 475, Ö 170-10 | Swedish Supreme Court — English translation (Jus Mundi) |
| Sedelmayer v Russia (Germany) | Cologne courts, 2006–2008 (judicial sale) | Facts recounted in ECtHR, Sedelmayer v Germany |
| SNPC v Walker / Connecticut Bank | Cass. 1re civ., 6 Feb 2007 | Légifrance |
| Commisimpex v Congo | Cass. 1re civ., 13 May 2015, n° 13-17.751 | Légifrance |
| Creighton Ltd v Government of Qatar | Cass. 1re civ., 6 Jul 2000, n° 98-19.068 | Jus Mundi (arrêt) |
| NML Capital v Argentina | Cass. 1re civ., 28 Sep 2011; 28 Mar 2013 | CAHDI database |
| NOGA v Russian Federation | Paris Cour d’appel, 10 Aug 2000; (2001) Rev Arb 114 | Reported — see Redfern & Hunter (7th edn) ch 11 |
| Elliott Associates LP v Peru | Brussels C.A., 8th Ch., 26 Sept 2000 (not reported) | Analysed in BIS Papers 72 |
| Stati v Kazakhstan (English referral) | [2020] EWHC 916 (Comm) | BAILII; Judiciary (PDF) |
| Sistem Mühendislik v Kyrgyz Republic | Swiss Fed. SC, 5A_681/2011, 23 Nov 2011 | Kluwer Arbitration Blog |
| FSIA execution provisions | 28 U.S.C. §§ 1609–1611 | Cornell LII — § 1610; § 1611 |
| State Immunity Act 1978 | ss 13–14 | legislation.gov.uk |
Strong secondary — primary not yet fully read
Sedelmayer's German Cologne auction (AJIL; ECtHR Sedelmayer v Germany); the Amsterdam Kashagan attachment (trade-press and Law360); FG Hemisphere v DR Congo (Hong Kong CFA 2011). The Alcom [1984] AC 580 holding is taken from the case record and headnote.
Still to primary-check before client-facing use
The per-pourvoi operative outcome of SNPC v Walker, and the Belgian and Dutch courts' own texts in Stati (the English referral judgment is verified, the continental originals are not). The LETCO 659 F. Supp. 606 embassy/central-bank holding and the NOGA holding are corroborated by Redfern and Hunter on International Arbitration (7th edn, 2023), ch 11, but the primary opinions have not been read in full.