On November 6, 2024, the French Supreme Court rejected the enforcement of an interim award on jurisdiction in the legal saga opposing Malaysia to the heirs of the Sultan of Sulu and spanning several jurisdictions. The Supreme Court ruled that the arbitration clause in an 1878 agreement – and on the basis of which a US$15 billion award has since been issued against Malaysia – is null and void. This decision will presumably lead the French Supreme Court to annul the US$15 billion award itself next.

Ilona Trouyet
Ilona Trouyet is an associate in the Litigation Department and a member of the International Arbitration group.
She represents clients in complex commercial arbitration matters including post M&A and distribution agreements disputes in various industries such as aerospace, petrochemical and pharmaceutical.
Ilona earned her Master’s degree at Sciences Po Law School, during which she majored in commercial litigation and international arbitration. Prior to joining Proskauer, Ilona interned for two years in several law firms and international arbitration boutiques in France and the UK. She also spent a year working as a legal consultant for the World Bank’s Global Forum for Law, Justice and Development.
Ilona is fluent in French, English and Italian.
Exodus From The Energy Charter Treaty – What is Left of Europe’s Protections for Investors?
As of January 2024, France, Germany and Poland have officially withdrawn from the Energy Charter Treaty (ECT). Their decision to withdraw from the treaty follows a recent European Commission proposal for a mass exodus from the ECT by EU member states, which effectively will limit protections granted by the treaty previously enjoyed by direct investors and asset managers with portfolio companies in the energy sector.