Litasco begins process of ICSID arbitration against Bulgaria over Lukoil Bulgaria sanctions

5 March 2026

Litasco SA, a Geneva-based subsidiary of Lukoil, has submitted a notice of dispute to Bulgaria over Bulgaria’s decision to put its assets into administration because of US sanctions on Lukoil.

The US sanctioned Lukoil in October 2025. In November 2025, Bulgaria passed a law to seize control of Lukoil’s assets in Bulgaria. The US granted a licence allowing Lukoil Bulgaria to continue operations as a result. The legislation included a provision preventing any challenge to the government’s decision in Bulgarian courts.

The notice of dispute was filed under a 1991 Bilateral Investment Treaty between Switzerland and Bulgaria and the Energy Charter Treaty signed in 1994. Both treaties protect against the expropriation of assets. Arbitration will commence if a resolution is not reached between Litasco and Bulgaria. If arbitration commences, it will be before the International Centre for Settlement of Investment Disputes (ICSID).