Satoriagricultural Consultancy & Projects Management L.L.C. S.P.C v. T&R Productions LLC

At a glance

Parties

Satoriagricultural Consultancy and Projects Management LLC SPC (UAE), assignee of TV-Novosti (Russia), v. T&R Productions LLC (District of Columbia)

Case no.

Civil Action No. 25-1287 (BAH)

Court

United States District Court for the District of Columbia, Judge Beryl A. Howell

Forum and rules

Petition to recognize and enforce foreign arbitral awards under the New York Convention and the Federal Arbitration Act, 9 U.S.C. § 201 et seq.; default judgment under Federal Rule of Civil Procedure 55(b)

Treaty

New York Convention

Underlying award(s)

Three awards of the International Commercial Arbitration Court at the Chamber of Commerce and Industry of the Russian Federation (ICAC), Decisions M-187/2022, M-188/2022 and M-189/2022 (February 2024)

Sector

Media; television content production

Outcome

Default judgment granted (8 January 2026): all three awards recognized and enforced. The public policy exception did not apply even though the original award creditor, TV-Novosti, was later sanctioned by the United States.

Amount

Judgment of USD 13,984,502.00: USD 13,793,500.00 under the three awards (USD 3,054,000.00, USD 4,480,000.00 and USD 6,259,500.00) and USD 191,002.00 in arbitration costs, plus post-judgment interest under 28 U.S.C. § 1961. The ruble cost award (₽210,094.55) was not sought. The request to reserve prejudgment interest was denied.

The dispute

T&R Productions, a media company based in Washington, D.C., produced content for RT America under three agreements with TV-Novosti, a Russian state-owned not-for-profit media company. TV-Novosti paid in advance and terminated all three agreements on 14 April 2022. T&R Productions did not refund the advances for unrendered services within 180 days, so TV-Novosti began ICAC arbitrations in December 2022. The ICAC awarded refunds and costs in February 2024. On 20 August 2024 TV-Novosti assigned the awards to SCPM, a UAE company, for 2,000,000 Russian rubles (about USD 20,000). The United States sanctioned TV-Novosti on 13 September 2024. SCPM petitioned for recognition and enforcement, and T&R Productions did not appear.

Key holdings

1. The Court had subject-matter jurisdiction under 9 U.S.C. §§ 202–203. The awards arose from commercial relationships that were not entirely between U.S. citizens, because TV-Novosti is a Russian company. The Court had personal jurisdiction over T&R Productions as a D.C. company served through its registered agent in D.C. pp. 9–10
2. The respondent did not appear, so no Article V(1) defence, which requires proof from the respondent, could be considered. The non-arbitrability exception in Article V(2)(a) did not apply, because the disputes concerned funds for services under commercial contracts. p. 11
3. No transaction in the case violated U.S. sanctions. TV-Novosti was designated on 13 September 2024, after the assignment had been paid for on 27 August 2024. OFAC sanctions operate prospectively, and SCPM is not sanctioned. p. 13
4. The public policy exception in Article V(2)(b) is construed narrowly. It does not cover national political interests. Even awards owed directly to sanctioned parties have been recognized. pp. 12–15
5. Recognition of an award differs from payment, and recognition does not bar later OFAC enforcement action. The exception did not apply even though SCPM may have bought the awards at a "suspiciously enormous discount" in anticipation of the sanctions, and the U.S. government declined to take a position. pp. 15–16
6. Judgment was entered for USD 13,984,502.00 with post-judgment interest under 28 U.S.C. § 1961. The request to reserve ruling on prejudgment interest was denied because it would unnecessarily extend the litigation. pp. 16–17

Procedural history

1. 14 April 2022TV-Novosti terminates the three agreements in writing.
2. December 2022TV-Novosti starts ICAC arbitration proceedings against T&R Productions.
3. February 2024The ICAC panel decides all three disputes for TV-Novosti (Decisions M-187/2022, M-188/2022, M-189/2022).
4. 20 August 2024TV-Novosti assigns its interest in the agreements and awards to SCPM. Consideration is paid on 27 August 2024.
5. 13 September 2024OFAC designates TV-Novosti for sanctions.
6. 12 May 2025The petition is served on T&R Productions, which does not answer. The Clerk later enters default.
7. 10 September 2025The Court orders SCPM to show cause why the petition should not be denied as against public policy, and invites the United States to state its position.
8. 8 January 2026Memorandum Opinion: default judgment granted and the three awards recognized and enforced.

Tribunal, counsel and experts

Decided by

• Beryl A. Howell Judge, United States District Court for the District of Columbia

For the claimant

Glenn Kolleeny

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Keywords

• New York Convention
• recognition and enforcement
• public policy exception
• Article V(2)(b)
• default judgment
• OFAC sanctions
• Russia sanctions
• assignment of arbitral award
• ICAC
• TV-Novosti
• RT America
• Federal Arbitration Act
• post-judgment interest
• Executive Order 14024
• media production
• refund of advance payments

Summary generated with AI from the published documents — refer to the award for the authoritative text.