The February 2026 NAMRIA administrative map has reignited discussions on the Philippines’ dormant claim to Sabah (North Borneo). The map shows Sabah as a geographical approximation south of Mindanao. Image Source: businessmirror.com.ph

The court’s annulment of the final arbitral award ordering Malaysia to pay US$14.92 billion to individuals claiming to be Sulu heirs was but the latest in a series of legal defeats in Spain, France, Luxembourg and the Netherlands.

The staggering value of the initial award rested not on legitimate legal foundations, but on a colonial-era document of contested translation. The Sulu Sultan had “willingly surrendered” and ceded North Borneo and nearby islands to the British in two agreements in 1878 and 1903.

However, descendants of the Sultan argue the territory was leased, not ceded. They say Malaysia’s decision to halt symbolic payments to the Sulu heirs—payments it had continued after taking over from the British when the people of North Borneo opted to join the Federation—violated the original terms.

“The Sulu Sultan had “willingly surrendered” and ceded North Borneo and nearby islands to the British in two agreements in 1878 and 1903.”

Those symbolic payments of approximately $1000 per annum were only halted following the 2013 Lahad Datu Incident, during which so-called Royal Sulu Forces headed by Jamalul Kiram III invaded North Borneo, now the Malaysian state of Sabah, leading to dozens of civilian and military deaths.

Despite the Philippines and even members of the House of Kiram denouncing the violence, what followed was not reconciliation but an arbitral lawsuit of immense proportion launched by a Fuad Kiram and financed by litigation funder Therium. The lawsuit sought to claim the economic value of Sabah as a royal fief of Fuad Kiram and eight other Sulu claimants, though their status as heirs of the Sulu Sultanate is not recognized by the Philippines.

Critics have noted that this opportunism was made worse by the profit-driven interests of Therium, which had no previous interest in the history and politics of the region and stood to gain an undisclosed substantial percentage of the near $15 billion arbitral award. It’s widely speculated that Therium served as a driving force behind the suit and its European-oriented strategy given the Sulu claimants’ meagre means. However, these efforts led to the conviction of the presiding arbitrator for contempt of court and the withdrawal of Therium from direct litigation funding following widely reported layoffs.

“Critics have noted that this opportunism was made worse by the profit-driven interests of Therium, which had no previous interest in the history and politics of the region and stood to gain an undisclosed substantial percentage of the near $15 billion arbitral award.”

Where does this leave the disjointed Sulu House of Kiram?

In fact, it’s important to understand the "Sulu heirs" are not a unified group with a coherent leadership structure. It is a deeply fractured constellation of rival claimants, each dismissing the others as illegitimate, each with different relationships to armed groups, and different levels of culpability in the arbitral scheme that collapsed in Paris.

Muedzul Lail Tan Kiram, The Legitimate Heir Who Watched From Jolo

Muedzul Lail Tan Kiram, born August 28, 1966, is the eldest son of Mohammed Mahakuttah Abdullah Kiram, the last titular sultan of Sulu recognized by the government of the Philippines.

His credentials are the most formally documented of any living claimant. Both his father and grandfather were recognized by the Philippine Government as the Sultans of Sulu from 1950 to 1986. Muedzul was crowned the 35th Sultan of Sulu in a ceremony in Mainbung, Sulu in September 2012.

When the 2013 Lahad Datu incursion happened, he was one of the few voices from within the broader Kiram family who immediately and publicly condemned it, describing Jamalul as one of the many self-styled and illegitimate Sultans of Sulu.

Muedzul did not participate in the Paris arbitration, though advocates for the peaceful and lawful pursuit of Sulu claims. Meanwhile, the rival Fuad Kiram faction, which Muedzul casts as illegitimate, sued for nearly $15 billion. It’s a disparity that highlights not only the divisions within the House but incalculable greed.

Fuad Kiram, The Manufactured Royal

Indeed, Muhammad Fuad Abdullah Kiram and his supporters represent an extreme opposite to Muedzul. Prior to the violence of 2013 and together with Omar Kiram, a Filipino-Australian businessman who adopted the Kiram name to claim noble descent, Fuad built what investigators described as one of Southeast Asia's most audacious sovereign frauds.

Crucially, Fuad Kiram was not among the recognized members of the Kiram dynasty that previously received the symbolic payments. Instead, posing as royalty of the defunct Sulu Sultanate, the Fuad and Omar conducted a sprawling two-decade scheme that blended manufactured titles while misleading investors with claims of 3 trillion in hidden wartime gold.

Fraudulent knighthoods and ambassadorships under the fictitious "Royal Hashemite Sultanate of Sulu and Sabah" were sold alongside the staging of pseudo-royal ceremonies across the globe.

“Fuad Kiram was not among the recognized members of the Kiram dynasty that previously received the symbolic payments.”

Omar Kiram and Fuad Kiram, pictured together in 2006. Image Source: Royal Sulu

The $14.92 billion arbitration was the culmination of this scheme. Yet with its dismissal, Fuad’s militant connections draw even greater concern than his history of fraudulent action. Indeed, with the collapse of Therium’s litigation funding operation and the discrediting of Fuad’s royal pageantry, other violent or underhanded tactics still remain.

Foreshadowing this, on February 28, 2026, the domain of KnowSulu.ph was taken offline in a coordinated cyberattack routed through multiple jurisdictions. The attack came weeks before a critical hearing at the Royal Court of Jersey that was the first step to unveiling how Therium funded Fuad Kiram’s activities.

Designated Terrorist

More concerning still, Malaysia has since 2023 recognized Fuad Kiram as a founder alongside Jamalul III of the Royal Sulu Force that invaded Lahad Datu with over two hundred militants. For this, he was designated a terrorist.

Despite suffering heavy losses, the Royal Sulu Force did not formally disband and is believed to retain latent support within segments of the large Sulu diaspora in eastern Sabah.

This armed infrastructure is reinforced by overlapping networks. Nur Misuari, founder of the influential Moro National Liberation Front (MNLF) in the Southern Philippines, reportedly declared support for the 2013 Lahad Datu invasion and endorsed Fuad Kiram’s claim to the Sultanate. Several MNLF followers were suspected of joining the incursion, creating a direct bridge between the European arbitration fronted by Fuad Kiram and an armed separatist movement with a long history of cross-border violence. Misuari’s ties extend further, including documented associations with commanders in Abu Sayyaf, an infamous terror group.

Although the Philippine government has declared the group dismantled in several provinces, it continues to operate through resilient clan-based and familial Tausug kinship networks that cross the Philippine-Malaysian borders.

“Several MNLF followers were suspected of joining the incursion, creating a direct bridge between the European arbitration fronted by Fuad Kiram and an armed separatist movement with a long history of cross-border violence.”

This network and its latent threat may be the more concerning of Fuad Kiram’s associations. After all, what happens to such a movement when its fraudulent legal strategy collapses entirely?

Analysts see three possible trajectories. First, the network quietly dissolves as the collapse of the Paris award and scrutiny from Jersey proceedings erode the credibility and funding of figures like Fuad A. Kiram, leaving only a dormant grievance.

Second, remaining actors pivot strategically, shifting from international litigation to domestic politics in the southern Philippines—rebuilding legitimacy among Tausug communities, strengthening ties with Moro networks, and sustaining the Sabah issue as a mobilizing force.

Third, and most concerning, a hardened faction radicalizes. Under pressure from the failed $14.92 billion claim, remnants of Kiram-aligned groups could launch a smaller, symbolic incursion into Sabah to trigger a crisis, regain attention, and force negotiations.

The Region is Watching

The Philippines finds itself in a delicate position. As ASEAN chair in 2026, Manila must balance its long-standing historical claim over Sabah with the need to preserve regional stability and the gains of the Bangsamoro peace process.

Philippine officials are wary of appearing to provide any political cover to the more aggressive Kiram factions while simultaneously leveraging the issue ahead of the 2028 Philippine elections. Both the Duterte faction—traditionally vocal supporters of a Philippine claim—and the Marcos administration have resurfaced the issue.

Will Manila present an unambiguous position that armed action in pursuit of the Sabah claim will never be acceptable? Ultimately, with the closing of Fuad Kiram’s legal campaign, the question is how the dispute might transform and whether the spectre of armed violence, which ASEAN has worked hard to diminish, will be its continuation.

REFERENCES

Bernama. (2025, October 16). Sulu Case: Spanish Supreme Court Dismisses Stampa’s Cassation Appeal, Upholds Conviction.

Bloomberg. (2025, December 10). Malaysia Says Paris Court Annuls Final Award in Sulu Case. https://www.bloomberg.com

Bloomberg. (2026, March 26). Litigation Funder Fights Petronas Suit After $15 Billion Sulu Award Unravels. https://www.bloomberg.com

BusinessMirror. (2026, February 23). Updated Namria map stirs new debate on Sabah claim. https://businessmirror.com.ph

Global Arbitration Review. (2025, October 16). Spanish arbitrator’s conviction upheld in Sulu saga. https://globalarbitrationreview.com

Global Arbitration Review. (2026, January 27). The Paris Court of Appeal annuls USD 14.92 billion award against Malaysia. https://www.globalarbitrationnews.com

Inquirer.net. (2026, February 19). Namria releases updated PH map. https://www.inquirer.net

KnowSulu. (2025, June 6). FRAUD Kiram: The Royal Ruse of Professional Conmen, Fuad and Omar Kiram. https://know-sulu.ph

NAMRIA Official Website. Administrative Map of the Philippines (download). https://namria.gov.ph

Philippine News Agency (PNA). (2026, February 18). PH official maps, charts show maritime jurisdiction in WPS – NAMRIA. https://www.pna.gov.ph

Reuters. (2025, December 10). French court annuls cash bid by late sultan’s heirs in Malaysia land dispute. https://www.reuters.com