UniCredit, a German bank, had issued a number of bonds in favour of RusChemAlliance (RCA), a Russian company, in connection with the construction of LNG plants in Russia. The bonds were governed by English law and provided for disputes to be settled by Paris-seated arbitration under ICC Rules. Following the Russian invasion of Ukraine the construction contracts were terminated and RCA made demands under the bonds. However, UniCredit refused to pay on the grounds that payment was prohibited by EU sanctions. RCA commenced proceedings against it in Russia and in response, UniCredit commenced proceedings in England, seeking an anti-suit injunction to prevent RCA from continuing the Russian proceedings in breach of the arbitration agreement.