UK High Court Dismisses VTB’s £205m Claim over Sanctions Licence Amendments

On 19 December 2025, the UK Administrative Court (Mrs Justice Collins Rice) delivered its decision in PJSC VTB Bank v HM Treasury EWHC 3359 (Admin), rejecting VTB’s claim that the UK government acted unlawfully in its amendment of a sanctions-related General Licence, which in turn barred VTB from recovering ~£205 million from VTB Capital Plc, its insolvent UK subsidiary. VTB had challenged six different grounds under section 38 of the Sanctions and Anti-Money Laundering Act 2018. [2][10]

Administrators (Teneo Inc) value VTB’s proof of debt at ~£188 million, showing a discrepancy of ~£17 million compared with VTB’s £205 million claim. The judgment rejected VTB’s contention that licensing amendments imposed by OFSI unlawfully eroded its recovery rights. The court found no basis to set aside the decision. [1][3][2]

This decision is part of a larger narrative: VTB Capital PLC was placed into administration in 2022 following sanctions. Those sanctions froze assets, disrupted operations, and prevented normal debt servicing, leaving the UK-based unit without access to necessary liquidity. The court’s ruling confirms that changes to sanctions licences—even if detrimental to creditor claims—can be lawful when properly executed under statutory powers.[10]

Strategically, the ruling limits recourse for state-owned foreign banks subject to comprehensive sanctions who challenge government sanctions regulation under domestic law. It signals that UK law can structurally subordinate the claims of such institutions when public policy imperatives (sanctions) override creditor expectations. It also raises important precedents for how claims are valued and treated in administrations intertwined with sanctions: recognition of proof of debt vs administrator valuation, “trapped assets”, and creditor voting thresholds in schemes vs insolvency rules.[1]

Open questions include: whether VTB will appeal; how administrator distributions will be calculated and when will payments proceed; how “trapped assets” (e.g. in Russian depositories) will be managed; and what this means for other sanctioned entities with similar structures or claims. Also, the decision may influence how future General Licences are designed and amended to balance sanctions compliance with fair treatment of creditors.