That shift is captured in two cases now before its courts: the challenge brought by Roman Abramovich over sanctions enforcement, and the conspiracy claims tied to the Sulu arbitration itself.

Despite the details unique to each dispute, there is a clear trend in which Jersey is now being asked to look beyond litigation outcomes, but at the architecture of the legal campaigns and whether conduct was transparent and just.

This is particularly crucial to the reputation of Jersey given that the Channel Island has long been regarded as a financial haven due to its separate jurisdiction from the UK and what critics argue to be comparatively lax oversight.

The Sulu Award Is Gone. The Questions Are Not

After the Paris Court of Appeal annulled the US$14.92 billion Sulu award on 9 December 2025, the dispute ceased to look like a spectacular arbitral triumph and began to look like something else: a campaign whose legal foundations had not survived judicial scrutiny.

Malaysia subsequently launched a suit alleging unlawful means conspiracy in Jersey against figures connected to the Sulu claim, including the eight individuals claiming to be Sulu heirs, their lawyers, and their litigation funder, Therium. The question is no longer simply whether the award was legally unfounded, but how the claim was built, financed, coordinated and illegally sustained across jurisdictions.

Spain, the original seat of the Sulu arbitration, had originally appointed former arbitrator Gonzalo Stampa as sole arbitrator. This appointment was later annulled by Spanish courts and the process halted after it was found that Malaysia had been improperly forced into the arbitration.

“This appointment was later annulled by Spanish courts and the process halted after it was found that Malaysia had been improperly forced into the arbitration.”

Despite this, Stampa—allegedly at the instigation of the Sulu claimants’ lawyers in what would be a gross act of partiality—ignored the annulment and moved the seat of arbitration to Paris. What followed was a series of attempts to enforce a nearly $15 billion award by seizing Malaysian assets in various European jurisdictions. The efforts attempted to outpace news of the annulment in Spain, which would gradually be adopted by each jurisdiction. For these actions, Stampa was convicted of contempt of court.

Why the Abramovich Case Still Matters

The Jersey proceedings involving Roman Abramovich stem from the sanctions imposed by the UK following Russia’s invasion of Ukraine in February 2022. In March 2022, Abramovich was designated under the UK sanctions regime, triggering asset freezes that extended into Jersey, where authorities moved quickly to identify and restrain assets linked to him through local structures. By April 2022, the Royal Court of Jersey had granted orders freezing assets worth billions of dollars.

However, the case now centres on whether the structures holding those assets were properly disclosed, how control was exercised, and most recently, whether the information presented to the court meets the required standards of accuracy and completeness.

Abramovich launched a countersuit in 2025, claiming the island’s authorities unlawfully froze his assets as part of a politically motivated effort linked to UK sanctions. He argues that the asset freezes were based on false or incomplete evidence and that Jersey's actions were not legally justified.

“He argues that the asset freezes were based on false or incomplete evidence and that Jersey's actions were not legally justified.”

The Abramovich case matters in the aftermath of the Sulu arbitration despite the disparities in the two litigations because it shows what Jersey has become.

The island is no longer an offshore venue in which politically sensitive financial activity finds safe haven. Instead, it is becoming a jurisdiction in which the conduct, disclosure, record-keeping and procedural credibility behind those contentious activities are themselves placed under the microscope.

“It is becoming a jurisdiction in which the conduct, disclosure, record-keeping and procedural credibility behind those contentious activities are themselves placed under the microscope.”

In fact, in January 2026, the Royal Court ordered the government to pay Abramovich’s costs in one part of the case after revelations about a 2022 email-archive purge and delayed disclosure helped support bad-faith allegations. While the court didn’t find those allegations proven or award indemnity costs, it made clear that the disclosure issues couldn’t be ignored.

The latest hearing on April 13, 2026 deepened this shift. Jersey’s Royal Court flagged “obvious” concerns over how the government handled the data exercise, criticizing the disclosure process and demanding officials justify their actions under oath.

While this doesn’t equate to a final finding of conspiracy, it signals a major development. The court’s decision to demand a formal explanation shows a growing willingness to scrutinize the procedural integrity of state actions, even in a politically charged, high-stakes case like this. This, ultimately, is the real “Abramovich effect.”

A Court No Longer Content With the Surface

Jersey’s courts are evolving into a space not just for legal outcomes, but for examining the structures behind the litigation itself. In Abramovich’s case, the allegation is that Jersey mishandled data and disclosure in a politically charged sanctions dispute. Meanwhile, in the Sulu aftermath, the focus has shifted to claims of conspiracy, with accusations that the Sulu claimants and their lawyers may have colluded to influence a now-convicted arbitrator into contempt of court—potentially through communications and financial transactions linked to Jersey.

In both cases, the courts are no longer just considering the surface legal issues, but probing the background activities that enabled them, with Abramovich’s case forcing the court to examine the impact of missing records, delayed disclosures, and questionable practices.

“In both cases, the courts are no longer just considering the surface legal issues, but probing the background activities that enabled them.”

Similarly, the Sulu case in Jersey is evolving beyond questions of the arbitration’s outcome to scrutinize the possible conspiracy between the claimants, lawyers, and the arbitrator. Jersey’s role, whether in financial transactions or communications, could be crucial in uncovering how the legal campaign was influenced. Jersey is becoming more than a forum for resolving disputes—it’s where the court is now examining the integrity of the processes and the forces shaping them.

Taken together, the Sulu afterlife and the Abramovich proceedings suggest that Jersey is becoming less a venue for resolving disputes and more a forum for interrogating how those disputes are built long after the fact. That is the more consequential development after April 13, 2026—and why both cases, in different ways, have converged into a single Jersey story about long term accountability behind the litigation.

REFERENCES

Global Arbitration News. (2026, January 27). The Paris Court of Appeal annuls USD 14.92 billion award against Malaysia finding the underlying arbitration agreement to be inapplicable. https://www.globalarbitrationnews.com

Global Arbitration Review. (2025, December 3). Funder and counsel face conspiracy suit over Sulu affair. https://globalarbitrationreview.com

Jersey Evening Post. (2026, January 27). Government data purge “clearly require some explanation”. https://jerseyeveningpost.com

Jersey Evening Post. (2026, April 17). “Obvious” concerns over government handling of Abramovich data. https://www.jerseyeveningpost.com

Jersey Legal Information Board. (2026, April 13). Abramovich v Chief Minister of Jersey and Ors [2026] JRC 094. https://www.jerseylaw.je

Judicial Committee of the Privy Council. (2025, November 12). Roman Arkadyevich Abramovich (Appellant) v His Majesty's Attorney General and another (Respondents) (Jersey). https://www.jcpc.uk

KnowSulu (2026, March 19). A New Test for Jersey’s Offshore Financial Reputation. https://know-sulu.ph

KnowSulu. (2025, November 11). Corrupt arbitration? Questions grow over Stampa’s ties to Sulu claimants’ lawyers in Spain. https://know-sulu.ph

KnowSulu (2025, December 12). Jersey court greenlights counterclaims against Sulu heirs and funders. https://know-sulu.ph

KnowSulu (2026, January 2). Jersey’s Hidden Conspiracies: From Russian Billions to the Sulu Arbitration. https://know-sulu.ph

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