Foreign illegality and English courts: Do the Ralli brothers now have a sister?
by Patrick Ostendorf (HTW Berlin)
In the recent and interesting case of LLC Eurochem v Société Generale S.A. et al [2025] EWHC 1938 (Comm), the English High Court (Commercial Court) considered the extent to which economic sanctions enacted by a foreign jurisdiction (EU law in this instance) can impact the enforcement of contractual payment claims (governed by English law) in English courts. More broadly, the decision also highlights the somewhat diminishing role of the Rome I Regulation (and its interpretation by the European Court of Justice) in the English legal system, and probably that of conflict of laws rules in general.