WFO Enforcement After Lakatamia: Expanding Liability and Strengthening Reach

Worldwide freezing orders (WFOs) remain among the most formidable tools in asset recovery litigation, and recent case law has reinforced their reach and resilience. In this session, Payne Hicks Beach LLP and 33 Chancery Lane explore what happens after a WFO is granted.

Anchored in the Court of Appeal’s decision in Lakatamia Shipping Co Ltd v Su [2025] EWCA Civ 1389, the panel will examine the widening scope of liability for those who knowingly assist in breaches of a freezing order. The discussion will consider how the judgment confirms that foreign third parties can face civil consequences for facilitating dissipation, and why the Babanaft proviso offers no safe harbour to those seeking to avoid compliance.

With contributions from leading practitioners and barristers specialising in civil fraud, injunctive relief, asset recovery and enforcement the session will delve into:

• strategic considerations when seeking a WFO and once it is in place;

• practical enforcement challenges across jurisdictions;

• the increasing willingness of courts to hold third parties to account; and

• the evolving interplay between freezing relief, disclosure duties, and contempt.

This promises to be a lively and practical discussion for litigators, insolvency practitioners, fraud specialists, and anyone navigating the complexities of domestic and cross border asset recovery