Court of Appeal gives landmark judgment on the intersection of sanctions, insolvency and administrative law
On 30 October 2026, the Court of Appeal (the Master of the Rolls, the Vice President and Zacaroli LJ) handed down judgment dismissing an appeal by Russia’s second largest bank, VTB Bank.
The appeal challenged a decision by HM Treasury’s Office of Financial Sanctions Implementation (OFSI) to amend a General Licence in respect of the administration of its UK subsidiary, VTB Capital.
The judgment addresses some significant issues about the intersection between sanctions, insolvency and administrative law.
Tom Rainsbury, led by Sir James Eadie KC and Thomas Munby KC, acted for HM Treasury instructed by the Government Legal Department.
William Day, with Tim Owen KC and Tim James-Matthews, acted for VTB Bank instructed by PCB Byrne. William continues to act for VTB Bank in parallel insolvency and restructuring proceedings arising from VTB Capital’s administration.
The judgment has neutral citation [2026] EWCA Civ 1373 and can be accessed here. A summary of the judgment can be accessed here.
