Transnational Bankruptcy under Economic Sanctions: Confl ict of Laws Issues and Protection of Russian Creditors' Interests

The purpose of the paper is a comprehensive analysis of transnational bankruptcy problems under economic sanctions in order to identify conflict of laws issues and develop mechanisms for protecting the interests of Russian creditors. An analysis of the judicial practice of the Russian Federation and foreign jurisdictions allowed us to identify the main problems of foreign decisions recognition, cooperation of courts and distribution of bankruptcy estate. Based on the study of legal regimes of various states and statistical data, trends in the transformation of the institution of cross-border insolvency under the influence of sanctions pressure have been identified. Ways to improve legislation and practice of applying norms on cross-border bankruptcy to ensure effective protection of the rights of Russian creditors are proposed.