On December 12, 2025, Melling, Voitishkin & Partners hosted SIAC Registrar Vivek Neelakantan and Deputy Counsel Margarita Drobyshevskaia in Moscow for a practical discussion on the arbitration centre’s relevance to Russian companies.
The meeting offered a detailed overview of SIAC’s procedures and its role in the current geopolitical landscape.
Below is a summary of the key insights and answers to the most pressing questions raised during our discussion.
The Growing Relevance of SIAC: Statistics and Trends
The increasing number of Russia-related cases at SIAC prompts a closer look at the underlying trends and statistics. The number of Russian parties in SIAC arbitrations has shown an upward trend, rising from 3 in 2020 to a notable high of 26 in 2024. The rising caseload suggests that SIAC stays relevant for Russian businesses despite geopolitical complexities.
According to SIAC’s 2024 statistics, its caseload is led by trade-related disputes, with trade (29%) and maritime/shipping (11%) together constituting a dominant 40% of all new cases. This is followed by a significant number of disputes in the commercial (19%), corporate (12%), and construction/infrastructure (11%) sectors. This diverse caseload, with its strong focus on trade, commodities, and industrial sectors, aligns well with the structure of Russia’s key exports such as energy, metals, fertilizers, and agricultural goods.
A breakdown of the governing law for these cases between 2020 and 2024 further reveals that English law remains dominant, followed by Singapore law and Indian law, along with several other countries' laws being applied.
SIAC’s Strategic Position in Asia
A key factor driving SIAC’s success, particularly in disputes involving Indian and Chinese parties, is its perceived neutrality. For parties from these economic powerhouses who are often hesitant to arbitrate in each other’s home jurisdictions, Singapore offers a safe middle ground. This perception of being truly independent is a cornerstone of SIAC’s appeal. Furthermore, SIAC offers an unparalleled level of experience in handling disputes involving both Indian and Chinese parties simultaneously. SIAC’s extensive caseload with both provides it with a unique dual perspective that is valued in cross-border transactions.
SIAC’s neutrality extends to practical advantages for Russian clients. Singapore boasts a strong, independent local bar which makes it possible for Russian and other sanctioned entities to secure high-quality legal representation in international arbitrations and local court proceedings.
Finally, SIAC differentiates itself through its 'involved' approach to case administration. SIAC’s Secretariat actively supervises the progress of each case and conducts a scrutiny of all draft awards — a quality control measure aimed at enhancing the clarity and enforceability of the final award.
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Navigating Sanctions: Practical Challenges and Solutions
One of the core issues of Russia-related dispute resolution revolves around the challenges posed by sanctions. As an independent, neutral, non-governmental institution based in Singapore, SIAC continues to accept and administer arbitrations that involve Russian parties, including parties that may be subject to various sanctions regimes. SIAC has likewise remained neutral in cases involving other designated parties from other comparable jurisdictions (like Iran or Myanmar, just to mention a few). It has not posed any significant issue for SIAC to administer those cases.
While Singapore has implemented its own sanctions related to Russia, they are very limited and primarily target financial institutions dealing with a few designated banks, without affecting non-bank entities or individuals, and contain an exception for the provision of legal services.
Two practical questions that may come up in sanctions-complicated disputes are the payment of arbitration fees and costs and the appointment of arbitrators.
Payments
SIAC has not encountered significant administrative issues in receiving payments from Russian parties, regardless of whether they are subject to sanctions.
Arbitrator appointment
SIAC tends to appoint arbitrators who the parties consider to be fully neutral.
Singapore as Seat of Arbitration
Singapore is a very popular seat for international arbitration, backed by a generally pro-arbitration judiciary and regulatory framework. A key factor underpinning this is the country’s political stability. Singapore offers a legal and business environment that is very predictable — a significant asset for businesses that value consistency and do not want to see laws and institutions change with every political cycle. In a large proportion of SIAC’s cases, Singapore is the chosen seat. However, it is important to note that under the SIAC Rules (Rule 36.1), if the parties have not agreed on a seat, the tribunal has the authority to determine it, providing a mechanism for flexibility. Among other things, this means that in such situations the tribunal may determine a sanctions-neutral seat, ensuring that the parties are given a fair opportunity to be heard.
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Award Annulment and Award Enforcement
Award annulment
The grounds for annulling an award in Singapore largely mirror the UNCITRAL Model Law, with two additions: if the making of the award was induced or affected by fraud or corruption, or a breach of the rules of natural justice occurred in connection with the making of the award by which the rights of any party have been prejudiced. A breach of natural justice occurs when a tribunal fails to give a party the opportunity to be heard on a crucial point, and this failure causes prejudice. This is reinforced by the very low success rate for award challenges in Singapore giving users confidence in the finality of awards in Singapore-seated arbitrations. As a general rule, Singapore’s courts are not interventionist, but they are vigilant guardians of due process.
Award enforcement
The ultimate test of any arbitration is the enforceability of its award. SIAC awards are regularly enforced worldwide. In India, for example, not a single SIAC award has been set aside or refused enforcement in the last decade, across more than 1,100 cases involving Indian parties. Positive enforcement experiences have also been confirmed in China, the UAE, the US, and the UK. This success is partly attributed to SIAC’s scrutiny process, where the SIAC’s Secretariat reviews every draft award to ensure its reasoning is sound and all procedural requirements are met, thereby enhancing its enforceability.
By and large, SIAC offers a reliable path to Russian users of arbitration to resolve their international disputes, especially with Asian counterparties. The key to success, however, lies not just in choosing the institution, but in deeply understanding its practical nuances, from navigating payment hurdles to strategically appointing a neutral tribunal. Ultimately, for Russian businesses operating in a complex global market, a well-informed approach to dispute resolution is no longer just a legal formality but a critical component of strategic risk management.
