Interaction between insolvency law and sanctions: judgment handed down in PJSC VTB Bank v HM Treasury

On 19 December 2025, the Administrative Court (Mrs Justice Collins Rice DBE CB) handed down judgment in PJSC VTB Bank v HM Treasury (Defendant) and VTB Capital Plc (in administration) (Interested Party) [2025] EWHC 3359 (Admin). 

In a case raising issues about the interaction between insolvency law and sanctions, the Court dismissed a claim by Russia's second largest bank under s.38 Sanctions and Anti-Money Laundering Act 2018, seeking to challenge a decision by the Office of Financial Sanctions Implementation to amend a General Licence relating to the administration of VTB Bank's insolvent UK subsidiary.

Thomas Munby KC appeared with Sir James Eadie KC of Blackstone Chambers and Tom Rainsbury of Three Verulam Buildings (instructed by the Government Legal Department) on behalf of the successful Defendant.

Read the full judgment: PJSC VTB Bank v HM Treasury.