Half a billion on foreign consultants: in which disputes is Ukraine defending its interests?
In 2025, the Ministry of Justice handled 24 cases in foreign jurisdictions and spent over $12.6 million (≈ 531.5 million UAH) on foreign legal counsel out of the budgeted 554.3 million UAH. These amounts cover various types of disputes, countries, courts, and arbitration proceedings.
Disputes and Arguments
In accordance with the law, the Ministry of Justice represents the state’s interests in foreign judicial bodies in cases involving a foreign entity and Ukraine. To this end, the ministry has special divisions dedicated to judicial matters. However, when a dispute goes beyond national jurisdiction and enters the realm of international arbitration or foreign court proceedings, the state engages external legal counsel.
Funding for such services is provided under budget program KPKVK 3601150. In particular, it covers expenses related to the protection of Ukraine’s rights and interests during the resolution of disputes and the consideration abroad of cases involving a foreign entity and Ukraine.
As is our tradition (research results from previous years can be found here and here), we requested a list of cases pending before foreign courts and under consideration by the Ministry of Justice in 2025. We supplemented the response received from the country’s main legal authority with data from the Prozorro portal, as well as public media reports on disputes, based on which we compiled our own summary table.
This allowed us to analyze the state’s international portfolio: where exactly the disputes were concentrated, who the state is suing, which advisors it engages, and what expenses it incurred over the course of the year. It is worth noting here that the data obtained does not reflect the full cost of each case, but rather a snapshot of expenses specifically for 2025, as some proceedings began earlier and will continue.
The dispute portfolio covers several categories of proceedings. The largest group consists of investment disputes against Ukraine. Alongside these are commercial and infrastructure disputes involving government agencies, a separate segment of cases involving the Ministry of Defense against foreign counterparties, as well as some cases that do not fit into the usual conflict model.
In investment, commercial, and post-arbitration disputes, the Ukrainian side builds its position both on substantive objections to the claims and on procedural arguments. Counsel challenge the jurisdiction of arbitral tribunals and the admissibility of claims, object to procedural actions that could weaken the state’s position, and address issues of public policy, procedural estoppel, admissibility of evidence, and the scope of document disclosure. In certain cases, the position involves opposing the enforcement of arbitral awards abroad, challenging foreign court decisions, protecting sensitive information from disclosure, and demonstrating the separation of state-owned companies and banks from the Government of Ukraine when claimants seek access to information regarding the state’s assets or financial activities.
Where, with whom, and through whom
Ukraine’s international litigation presence in 2025 was concentrated in several key jurisdictional centers. The most prominent of these is Washington, D.C., home to the International Centre for Settlement of Investment Disputes (ICSID). This is a specialized arbitration institution for resolving investment disputes between states and foreign investors. It is through ICSID that a significant portion of disputes are heard in which investors assert claims against Ukraine based on international investment protection agreements.
The SCC Arbitration Institute—the Arbitration Institute of the Stockholm Chamber of Commerce—also plays a role, administering international commercial and investment arbitrations. There are disputes before the International Court of Arbitration of the International Chamber of Commerce (ICC)—an institution headquartered in Paris that administers commercial arbitrations, particularly in disputes related to infrastructure projects. There are also a number of national jurisdictions where issues of enforcement or local support are resolved.
The geography of the opposing parties is also telling. A significant portion of investment claims originate from companies registered in EU countries and the United Kingdom that had or have business interests in Ukraine.
Among them are:
- ABH Holdings S.A., a Luxembourg-based holding company;
- CTF Holdings S.A., a Luxembourg-based holding company;
- E.M.I.S. Finance B.V., a Dutch financial company;
- Enwell Energy plc, a British oil and gas company;
- Smart Energy B.V., a Dutch gas production company;
- Modus Energy, a Lithuanian renewable energy company;
- Misen Enterprises AB, a Swedish hydrocarbon production company.
Russian disputes can also be highlighted separately—primarily with VEB.RF, PJSC Tatneft, the Republic of Tatarstan and its Ministry of Land and Property Relations, as well as commercial and infrastructure disputes with Chinese and Italian companies.
This specific approach is reflected in the model for engaging external advisors: depending on the jurisdiction, the stage of the dispute, and local law, the state works with teams that vary in function. For major investment and commercial disputes, international firms specializing in arbitration, cross-border litigation, and handling disputes involving states are engaged:
- A&O Shearman, a global law firm formed following the merger of Allen & Overy and Shearman & Sterling, with a practice in international arbitration in commercial and investment disputes;
- Hogan Lovells, an international firm handling commercial and investment arbitration and public international law matters;
- Quinn Emanuel Urquhart & Sullivan, a firm focused specifically on litigation and arbitration;
- Foley Hoag, a firm known for representing sovereign states in international disputes;
- Clifford Chance and Latham & Watkins, global firms with international arbitration practices in the energy, finance, construction, and infrastructure sectors;
- Clyde & Co, an international firm with practices in insurance, construction, energy, and infrastructure disputes;
- Holland & Knight, a firm with practices in international arbitration and cross-border litigation;
- Carter-Ruck, a British firm known for its expertise in international law, commercial disputes, media, and reputation protection.
At the same time, in cases requiring action within a specific national jurisdiction, local counsel are engaged to provide representation in the courts of the relevant country, perform procedural actions, or assist with recognition and enforcement proceedings.
The distribution of fees in 2025 was extremely uneven: two firms—A&O Shearman and Quinn Emanuel—accounted for approximately 74% of all payments to foreign counsel (≈ $9.3 million out of $12.6 million). The remaining firms share less than a quarter of the budget.
Where Risks and Money Are Concentrated
The largest expenditures in 2025 were concentrated where high financial risk, complex jurisdiction, and the need for intensive procedural support converge for the state. This is evident in major investment disputes.
For example, in the case of VEB.RF’s lawsuit against Ukraine, where the amount of claims exceeds $3.2 billion plus interest, there were two payments of fees to the counsel in 2025—$1.5 million and $2.4 million. This dispute arose after Ukraine put up for sale and effectively sold 99.77% of the shares in Prominvestbank, which belonged to a VEB-affiliated entity. In response, the Russian side filed an investment claim, viewing these actions as a violation of its rights as an investor.
In the ABH Holdings case (claims totaling $513.1 million), the fees amounted to €1 million and €2.8 million. This dispute lies at the intersection of investment arbitration, banking law, and sanctions regulation, as it involves claims related to the expropriation of Sens Bank (formerly Alfa-Bank).
Significant costs were also recorded in the Modus Energy case—$338,500 and $561,300—although the amount of the claims here is significantly lower than in the largest investment disputes, totaling $22.7 million plus annual interest. The Lithuanian company invested in solar power plants in Ukraine, but due to legislative changes in 2020, the “green tariff” was reduced. The investor claimed that this violated the Energy Charter and caused losses to the business.
In the Misen Enterprises case, where the amount of the claims is $810.3 million, legal fees amounted to $750,000. The subject of the dispute is a gas production project in Ukraine. The plaintiff attributes the violation of its rights to the introduction of a 70% royalty rate for gas extraction within the framework of a joint venture, which, according to the plaintiff, led to the termination of the relevant agreement.
As can be seen from the figures provided, the value of the claim does not always correlate directly with legal counsel fees. For example, in the VEB.RF case, the largest amount of claims is accompanied by high payments to counsel. In contrast, in the Misen Enterprises case, where the amount of claims is also significant, annual legal fees appear notably more modest. In the Modus Energy case, conversely, the amount of the claims is smaller compared to the largest investment disputes, but the costs of legal counsel remain substantial. This can be explained by the specific circumstances of the case itself—most factors depend on the stage of the proceedings, the intensity of the proceedings during the relevant period, and the nature of the procedural actions the counsel performed for the Ministry of Justice in 2025.
The Ministry of Defense’s Share
A separate category consists of cases involving the Ministry of Defense that arose under martial law. The existing disputes differ from investment arbitrations not only in terms of the parties but also in procedural logic. While in investment disputes Ukraine primarily defends itself against claims, here, on the contrary, it seeks to recover funds from foreign counterparties, enforce awards, or secure their recognition in the relevant countries.
The dispute with CENTCOM Global concerns a contract dated March 16, 2022, for the supply of 152-mm artillery ammunition. Ukraine insists that the contract was not properly performed and is seeking to recover $18.2 million plus interest. The Regulus Global case concerns another defense contract—dated June 23, 2022—for the supply of 122-mm shells. Here, the state also alleges that the supplier breached its obligations and is claiming $13 million plus interest.
The Turkish case is related to the Farmtr case concerning a contract dated March 14, 2022, for the supply of ballistic vests. After the supplier failed to deliver, the parties entered into a mediation agreement under Turkish law, in which the debtor acknowledged a debt of €16.8 million. A portion of this amount—€3 million—was paid, but the remainder remains outstanding. Therefore, Ukraine is seeking to recover at least €13.8 million.
Some cases have already moved into the enforcement phase of decisions rendered in favor of the Ministry of Defense by the International Commercial Arbitration Court at the Ukrainian Chamber of Commerce and Industry. For example, the Slovenian case IZOP-K concerns debt under two contracts dated March 10, 2022, which is publicly linked to an advance payment for body armor and other ballistic equipment. In the Czech cases AKM GROUP-CZ and 7.62 S.R.O., the subject of the disputes was a breach of supply terms under defense contracts. In the 7.62 S.R.O. case, court documents indicate that the contract concerned body armor with a set of plates, some of which were delivered in substandard quality. The Polish case involving WDI is also related to a supply contract, which public sources associate with body armor, and is already at the stage of recognition and enforcement of the arbitral award in Poland.
The geography of the Ministry of Defense’s disputes differs from that of major investment disputes: Switzerland, Turkey, Slovenia, the Czech Republic, and Poland are involved here. At the same time, not every case in this group required the engagement of a separate foreign counsel for full representation. In some cases, the Ministry of Justice handled the representation entirely on its own; in others, it limited itself to providing advisory services. However, where action was required in specific national courts or enforcement proceedings, local firms operating in the relevant jurisdiction were engaged. This is why the list of advisors includes Pekin ve Bayar, KIRM PERPAR, Banyaiova Vozehova, and Łaszczuk i Wspólnicy.
The structure of the Ministry of Justice’s case portfolio in 2025 indicates that the state is spending resources not only on defending against multimillion-dollar claims but also on attempts to recover funds, ensure the enforcement of decisions, and defend other interests abroad.
