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Germany's Deutsche Bank has brought a complaint at Russia's Constitutional Court challenging provisions of the Arbitration Procedure Code (APC), known as the "Lugovoy law," which allow Russian courts to prohibit foreign companies from applying foreign arbitration proceedings against sanctioned Russian parties. Specialist publication Global Arbitration Review announced the filing of the complaint by Deutsche Bank. The Constitutional Court docket lists two complaints by Deutsche Bank that are currently under preliminary review.

The bank claims that Articles 248.1 and 248.2 of the APC, which define the exclusive jurisdiction of Russian arbitrazh (commercial) courts in disputes involving sanctioned persons and the possibility of issuing anti-claim injunctions in their favour, discriminate against arbitration proceedings conducted outside Russia.

Deutsche Bank was one of five German institutions acting as guarantors for a transaction between RusChemAlliance (RCA, a joint venture between Gazprom and RusGazDobycha) and its former contractor Linde (Germany). In 2021, they signed a contract to build a gas processing plant in Ust-Luga, Leningrad Region. RCA made an advance payment of €2 billion to Linde, but in May 2022, Linde announced it was suspending work, citing EU sanctions. The guarantor banks (UniCredit, Deutsche Bank, Commerzbank, Bayerische Landesbank, and Landesbank Baden-Württemberg) also refused to return the money to RCA, citing sanctions.

The guarantee agreement provided for disputes to be resolved through arbitration at the International Chamber of Commerce (ICC) in Paris. Deutsche Bank asked the ICC arbitration court to recognise that, due to the EU sanctions, it was not obliged to make payments to RCA under a bank guarantee.

In 2024, a Russian court upheld RCA's claims against all five banks, with liability allocated as follows: UniCredit €463 million, Bayerische Landesbank €273 million, Deutsche Bank €238 million, Commerzbank €95 million, and Landesbank Baden-Württemberg €52 million. However, the court denied the claim for foreclosure on Deutsche Bank's wholly-owned Russian subsidiaries —Deutsche Bank LLC and Techcenter Deutsche Bank LLC.

RCA stated that the terms of the arbitration clause, under which disputes between the parties were to be resolved under ICC arbitration rules in Paris, were unenforceable for a number of reasons. In October 2024, the Arbitrazh (Commercial) Court of St. Petersburg and Leningrad Region prohibited Deutsche Bank from continuing proceedings in the ICC Arbitration Court in Paris.

Earlier in 2025, a similar complaint was filed with the Constitutional Court by the German company OWH, a former subsidiary of VTB Group in Europe. However, the Constitutional Court of Russia declined to consider it.