Opinion of the Advocate General — ECLI:EU:C:2026:110
Date: 2026-02-26
Language of the case: Swedish

Summary C-802/24 – 1 
Case C-802/24 
Summary of the request for a preliminary ruling pursuant to Article 98(1) of 
the Rules of Procedure of the Court of Justice 
Date lodged:  
20 November 2024 
Referring court:  
Svea hovrätt (Sweden) 
Date of the decision to refer: 
18 November 2024 
Applicant:  
NV Reibel 
Defendant:  
JSC VO Stankoimport 
  
Subject matter of the main proceedings 
A Belgian undertaking concluded an agreement with a Russian undertaking on the 
exportation of goods. The Belgian authorities refused to grant an export licence 
with reference to the restrictive measures in force against Russia. The resulting 
contractual dispute between the undertakings was settled by arbitration. The 
Belgian undertaking brought an application against the arbitration award before 
the referring court. The question now is to what extent do the provisions on 
restrictive measures limit the possibilities for settling, in private arbitration 
proceedings, disputes such as those at issue in this case. 
Subject matter and legal basis of the request 
Request for a preliminary ruling pursuant to Article 267 TFEU on the 
interpretation of Article 11 of Council Regulation (EU) No 833/2014 of 31 July 
2014 concerning restrictive measures in view of Russia’s actions destabilising the 
situation in Ukraine (OJ 2014 L 229, p. 1). 
SV 
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Questions referred for a preliminary ruling 
1. Must Regulation 833/2014 be interpreted as meaning that parties to an 
agreement are precluded from reaching an agreement out of court on claims 
which, under Article 11(1) of that regulation, are not to be satisfied and that 
amicable settlements reached by parties to an agreement on claims covered by 
Article 11(1) are null and void in civil law? 
2. Must Article 11 of Regulation 833/2014 be interpreted as meaning that a 
national court hearing an application for setting aside or annulment of an 
arbitration award in which that article has been applied must determine of its own 
motion whether the arbitration tribunal’s application of the law is compatible with 
Regulation 833/2014 and, in such a case, must the national court annul or set aside 
the arbitration award in whole or in part if the arbitration tribunal’s application of 
the law was contrary to the regulation? 
3. Must Article 11(1) of Regulation 833/2014 be interpreted as not precluding 
satisfaction of a claim if the claim concerns 
(a) repayment of an advance payment in respect of goods which were never 
supplied on account of measures under the regulation? 
(b) interest on a claim mentioned in (a)? 
Provisions of European Union law relied on 
Article 21 TEU, in particular Article 21(1), (2)(a) to (c) and (3). 
Articles 1, 2, 8 and 11 of Regulation 833/2014: 
Several versions of Regulation 833/2014 are at issue in the case before the Svea 
hovrätt (Svea Court of Appeal, Stockholm, Sweden). When the parties concluded 
their agreement, the regulation in force at the time was the version as amended by 
Council Regulation (EU) 2015/1797 of 7 October 2015. When the Belgian 
authority and the Conseil d’Etat (Council of State, Belgium) refused the export 
licence, the regulation in force at the time was the version as amended by Council 
Regulation (EU) 2017/2212 of 30 November 2017. Lastly, when the arbitration 
tribunal made its award, the regulation in force at the time was the version as 
amended by Commission Implementing Regulation (EU) 2019/1163 of 5 July 
2019. At the time the Svea Court of Appeal is now making its request for a 
preliminary ruling, the regulation in force is the version as amended by 
Commission Implementing Regulation (EU) 2024/2465 of 10 September 2024. 
Articles 1(a), 2(1), 8(1) and 11(1) to (3) have, in so far as they are relevant to the 
questions of the Svea Court of Appeal, the same wording as all the previous 
versions. However, in the current wording Article 1(a) concerning dual-use goods 
and technology refers to a different regulation than before, Article 2(1) has been 
tightened up to apply even if the products are not intended for military use, and 
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Article 8(1) has been drawn up regarding mitigating circumstances, among other 
things. 
Provisions of national law relied on 
Lagen om skiljeförfarande (SFS 1999:116; Law on arbitration proceedings) 
Under the first subparagraph of Paragraph 1 of the Law on arbitration proceedings 
(‘the Law on arbitration’), disputes concerning matters which the parties may 
settle by agreement may be submitted to one or more arbitrators for decision 
(arbitrability). 
Under Paragraph 33(1) of the Law on arbitration, an arbitration award is to be null 
and void, inter alia, (1) where it involves the examination of a question which, 
under Swedish law, may not be decided by arbitrators (lack of arbitrability) or (2) 
where the arbitration award or the manner in which it was arrived at is manifestly 
incompatible with the Swedish legal order (ordre public).  
Lagen om vissa internationella sanktioner (SFS 1996:95; Law on certain 
international sanctions) 
The requirement under Article 8 of Regulation No 833/2014 that Member States 
lay down rules on penalties applicable to infringements of that regulation and take 
all measures necessary to ensure that those rules are applied was dealt with in 
Sweden by the Law on certain international sanctions (1996:95; ‘Law on 
sanctions’). The Swedish Government considered that the requirements laid down 
in Article 8 of Regulation 833/2014 are fulfilled in particular by Paragraphs 8 to 
14 of the Law on sanctions, which contain rules on penalties, prosecution, 
confiscation and coercive measures. Infringements of the rules on prohibition laid 
down in Regulation 833/2014 were thus considered by the Swedish Government 
to be caught by the criminal liability laid down in the Law on sanctions. 
Succinct presentation of the facts and procedure in the main proceedings 
1 The parties to the proceedings are NV Reibel (‘Reibel’), on the one hand, and JSC 
VO Stankoimport (‘Stankoimport’), on the other. Reibel is a Belgium-registered 
undertaking active in logistics and international transportation of goods. 
Stankoimport is a Russia-registered undertaking which imports metal products 
and machinery into Russia. 
2 On 8 December 2015, the parties concluded an agreement (‘the agreement’) 
pursuant to which Reibel would sell and supply goods and provide certain services 
to Stankoimport. The agreement contained an arbitration clause under which all 
disputes, other than those falling within the jurisdiction of national courts, would 
be subject to arbitration proceedings. Swedish law would apply in the event of 
arbitration proceedings. 
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3 In addition, under the agreement European sanctions against Russia would not be 
considered to constitute force majeure and such sanctions would not release the 
parties from their obligations under the agreement. 
4 Stankoimport prepaid part of the contract price to Reibel. 
5 On 23 March 2017, a Belgian authority decided not to issue a licence for Reibel to 
export the goods in question to Stankoimport. The decision was adopted with 
reference to Regulation 833/2014 and also to Council Regulation (EC) 
No 428/2009 of 5 May 2009 setting up a Community regime for the control of 
exports, transfer, brokering and transit of dual-use items and Council Common 
Position 2008/944/CFSP of 8 December 2008 defining common rules governing 
control of exports of military technology and equipment. 
6 As grounds for its decision, the Belgian authority stated that the goods which 
Reibel intended to export to Stankoimport were intended for the production of 
helicopter parts. Reibel lodged an appeal against that decision with the Belgian 
Council of State, which dismissed the appeal on 26 September 2017. According to 
the Belgian court, it could not be confirmed that the goods in question were not 
intended for the production of parts for the military vehicle industry. 
7 Since Reibel did not obtain an export licence, it did not supply the goods to 
Stankoimport pursuant to the agreement. Reibel did not repay the entire advance 
payment. 
8 Stankoimport terminated the agreement and filed a request for arbitration. 
Arbitration proceedings 
9 In the arbitration proceedings, Stankoimport claimed that Reibel should be 
ordered to repay to it the advance payment, plus interest. Stankoimport further 
claimed that Reibel should be ordered to pay damages for breach of contract and 
other damages, plus interest. Lastly, it claimed reimbursement of its legal costs. 
10 Reibel contested Stankoimport’s claim. 
11 The arbitration tribunal granted Stankoimport’s claim for repayment of the 
advance payment, plus interest, and dismissed the other claims. In view of the 
outcome of the case, Reibel was also ordered to pay part of Stankoimport’s legal 
costs. 
12 According to the arbitration award, the agreement was valid at the time it was 
concluded, including in the context of Regulation 833/2014. In the view of the 
arbitration tribunal, the validity of the agreement was not affected by the refusal to 
grant an export licence. Nor did the arbitration tribunal find that there was 
anything to indicate that the agreement had been concluded with the aim of 
circumventing EU law. However, the arbitration tribunal did find that Reibel was 
prevented from fulfilling its contractual obligations, that is to say supplying the 
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goods to Stankoimport, as a result of the refusal to grant the export licence. The 
decision of the Belgian authority and the Belgian Council of State was interpreted 
by the arbitration tribunal as refusing the export licence as a ‘precautionary 
exercise’ because they considered that Reibel was unable to demonstrate that the 
goods could not also be for military use. 
13 In the view of the arbitration tribunal, the request for repayment, plus interest, 
does not constitute a claim which is prohibited from being satisfied under 
Article 11 of Regulation 833/2014. According to the tribunal, that article does not 
cover a claim for repayment of an amount paid for goods which were never 
supplied. In the tribunal’s view, such an amount and the related claim for interest 
do not indicate the performance of a prohibited transaction, but only aim to restore 
the parties to the position they were in before the agreement was concluded. As a 
starting point for its reasoning, the arbitration tribunal referred to the judgment of 
the Court of Justice of the European Union of 7 September 2020, Rosneft and 
Others v Council (C-732/18 P, EU:C:2020:727; ‘the judgment in Rosneft 2’), 
paragraphs 107 to 109. 
14 The tribunal noted that the right to repayment derives from the right of restitution 
under the United Nations Convention of 11 April 1980 on Contracts for the 
International Sale of Goods (CISG) and that the right to interest derives from 
statute. In the view of the arbitration tribunal, not granting Stankoimport the right 
to repayment and interest would constitute disproportionate application of 
Article 11 of Regulation 833/2014 in comparison with the judgment in Rosneft 2. 
However, the arbitration tribunal held that the other claims were covered by 
Article 11 of Regulation 833/2014 as they constituted an attempt to obtain 
financial advantage from Reibel’s failure to perform a prohibited transaction. 
Stankoimport’s claim for damages was therefore dismissed. 
Application before the Svea Court of Appeal 
15 Reibel brought an application before the Svea Court of Appeal and claimed that it 
should set aside the arbitration award. As grounds for its claim, Reibel stated, inter 
alia, as follows. The parties did not have an arbitration agreement covering the 
central issue in the dispute and the arbitration tribunal exceeded the limits of the 
task conferred on it when it addressed circumstances, without properly analysing 
them, concerning mandatory provisions in Belgium. That was likely to have 
affected the outcome. For the same reasons, the arbitration award is contrary to 
ordre public. In addition, Reibel argues that the arbitration award was issued out 
of time. 
16 Stankoimport contested Reibel’s claim and stated, inter alia, that the parties had a 
valid arbitration agreement, that Reibel never contested the arbitration tribunal’s 
jurisdiction during the arbitration proceedings and that the arbitration award was 
not issued out of time. 
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17 The Svea Court of Appeal decided that the arbitration award may not be enforced 
until further notice (stay of execution). 
18 In the course of the proceedings, the Svea Court of Appeal found reason to 
consider whether the issues examined by the arbitration tribunal were arbitrable 
under Swedish arbitration law. The Svea Court of Appeal also questioned whether 
Regulation 833/2014 constitutes part of the European Union’s legal order (ordre 
public) and whether the arbitration tribunal’s interpretation of Article 11 of 
Regulation 833/2014 was correct. 
Succinct presentation of the reasoning in the request for a preliminary ruling 
The question whether Regulation 833/2014 allows amicable settlement where 
restrictions apply 
19 As stated above, under Swedish law on arbitration arbitrability is determined by 
whether or not the parties are able to reach an amicable settlement on the claim at 
issue. Against that background, the question which the Svea Court of Appeal asks 
is whether or not the parties to a transaction affected by measures under 
Regulation 833/2014 have the right to settle amicably claims referred to in 
Article 11(1) of that regulation. 
20 Neither Regulation 833/2014 nor the Swedish Law on sanctions provides for any 
civil penalties, such as nullity, for example, for infringements of Regulation 
833/2014. Swedish law also lacks general provisions on the nullity of legal acts 
contrary to the law or accepted principles of morality. Nullity may instead derive 
from general principles of law. Whether an agreement which is contrary to the law 
is null and void, even though no law provides that that is the case, depends on 
whether the rule of law which has been infringed is based on considerations which 
can warrant a penalty of nullity. 
21 The wording of Article 11 of Regulation 833/2014 also indicates that it has no 
direct, civil-law effects between contracting parties, but is directed only at the 
authorities and courts hearing claims referred to in that article. Thus, Article 11(1) 
states that claims are not to be satisfied and Article 11(2) refers to proceedings for 
the enforcement of a claim. At the same time, however, such an interpretation is 
not entirely self-evident since the purpose of the regulation, which is to impose 
restrictive measures on certain exports to Russia and certain Russian actors, may 
seem to require, in order to be effective, that its provisions also have civil-law 
effects between the parties to an agreement affected by Regulation No 833/2014, 
for example if they settle out of court a claim which is prohibited from being 
satisfied under the regulation. 
22 It is also not entirely clear from the wording of Article 8 whether it is sufficient 
for Member States to impose criminal penalties for infringements under 
Regulation 833/2014, or whether civil penalties are also required. It is also 
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conceivable that transactions which are subject to criminal penalties under EU law 
should inherently not be valid under civil law, that is to say EU law can require 
that the transactions not be valid under national law. That may be so even if it is 
clear that a claim in accordance with an amicable settlement will not be 
enforceable in the EU. 
23 With regard to other, similar sanctions instruments, the Court of Justice has also 
placed a broad interpretation on the provisions as legitimate and indispensable, 
referring to the fact that the purpose of the regulations in question is to prevent 
any use of assets that would enable the regulations at issue to be circumvented and 
the weaknesses in the system to be exploited (see, for example, judgment of the 
Court of Justice of 11 November 2021, Bank Sepah, C-340/20, EU:C:2021:903, 
paragraph 56). 
24 In the judgment of the General Court referred to by the arbitration tribunal 
(judgment of 13 September 2018, NK Rosneft and Others v Council, T-715/14, 
EU:T:2018:544), the General Court also appears possibly to have reasoned that 
there may be civil-law effects of Regulation 833/2014, when it refers to ‘a remedy 
under civil law’ and states that [such a provision] ‘ensures the effectiveness of the 
restrictive measures at issue, by reflecting in private law the effects of 
measures … adopted by the European Union’ (see paragraph 206 thereof). 
25 The Svea Court of Appeal also notes that a somewhat similar question of 
interpretation to that which it is now raising appears to have arisen in respect of 
the substantively similar Article 11(1) of Council Regulation (EU) No 269/2014 
of 17 March 2014 concerning restrictive measures in respect of actions 
undermining or threatening the territorial integrity, sovereignty and independence 
of Ukraine. The Supreme Court of Latvia raised questions as to the legal effects of 
that article and in particular asked whether it would be permissible for the 
substance of claims such as those referred to in the article to be heard and 
determined if the operative part of the court’s judgment contained a statement that 
the judgment may not be enforced as long as the sanctions apply. However, that 
case is focused more on procedural issues as to how a court should deal with a 
claim and will not provide an answer to the question raised by the Svea Court of 
Appeal (judgment of the Court of Justice in Case C-480/24, Čiekuri-Shishki; see 
in particular Question 5 of the request for preliminary ruling). 
26 Although there is much to suggest that Regulation 833/2014 has no civil-law 
effects between the parties to an agreement affected by the regulation, the 
question of such effects, and thus also the question whether the parties have the 
possibility of amicably settling claims covered by Article 11 of the regulation, 
cannot, in the view of the Svea Court of Appeal, be considered clear or clarified 
against the background set out above. 
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The question whether Regulation 833/2014 forms part of the foundations of the 
European Union’s legal order 
27 According to the case-law of the Court of Justice, where its domestic rules of 
procedure require a national court to decide on setting aside an arbitration award 
on the ground that it infringes national rules relating to public policy, it must also 
take into account whether there has been failure to comply with EU rules of this 
type (see the judgment of the Court of Justice of 26 October 2006, Mostaza Claro, 
C-168/05, EU:C:2006:675, paragraph 35). In the light of that case-law, the Svea 
Court of Appeal asks whether Regulation No 833/2014 forms part of the 
foundations of the EU legal order in such a way that it must be taken into account 
in the judicial review of an arbitration award whose subject matter gives rise to the 
application of that regulation. 
28 According to recital 2 to Regulation No 833/2014, the aim of the restrictive 
measures laid down in that regulation is to promote a peaceful settlement of the 
crisis in Ukraine, which, according to the Court of Justice, is consistent with the 
objective of maintaining peace and international security, in accordance with the 
objectives of the Union’s external action set out in Article 21 TEU (judgment of 
the Court of Justice of 28 March 2017, Rosneft, C-72/15, EU:C:2017:236, 
paragraphs 115 and 150). 
29 In the view of the Svea Court of Appeal, that suggests that Regulation 
No 833/2014, in the light of its connection with the objectives of the Union’s 
external action under Article 21 TEU, may fulfil a particularly important function 
and possibly occupy a special position in the legal order of the Union. In that 
regard, the Svea Court of Appeal takes account of the fact that Regulation 
No 833/2014 constitutes mandatory provisions of EU law, the purpose and interest 
of which appear to be of great importance. Furthermore, that regulation could 
constitute a measure which is essential to the accomplishment of the tasks 
entrusted to the EU, in particular in the light of the objectives of the Union’s 
external action (see judgment of the Court of Justice of 1 June 1999 in Eco Swiss, 
C-126/97, EU:C:1999:269, paragraph 36, and Mostaza Claro, cited above, 
paragraph 37). 
30 An interpretation according to which Regulation No 833/2014 forms part of the 
foundations of the EU legal order would mean that it is for the national courts, in 
their formal review, the limits of which are prescribed by the primary rule, to 
carry out a review of the substance of arbitration awards whose subject matter 
gives rise to the application of that regulation. In addition, national courts, unlike 
arbitration tribunals, could request the Court of Justice to give a preliminary ruling 
on questions concerning the interpretation of that regulation (see the judgment in 
Eco Swiss, cited above, paragraph 40). 
31 At the same time, it is in the interest of efficient arbitration proceedings that 
review should be limited in scope and that annulment of an award should be 
possible only in exceptional circumstances (see the judgment in Eco Swiss, cited 
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above, paragraph 35, and the judgment in Mostaza Claro, cited above, 
paragraph 34). That suggests that the situations where national courts must carry 
out a review of the substance, on the ground that the arbitrational tribunal’s review 
concerned EU law relating to the public policy, should be reserved for the most 
important rules of EU law. 
32 The question whether EU regulations by which restrictions are imposed on third 
countries, including in any event Regulation 833/2014, occupy such a special 
position as mentioned above in the EU legal order cannot, against the background 
set out by the Svea Court of Appeal, be considered clear or clarified. 
The question whether it is compatible with Article 11 of Regulation No 833/2014 
to grant the right to repayment with interest 
33 In the event that Regulation 833/2014 does form part of the foundations of the EU 
legal order and the validity of the arbitration award thus depends on a correct 
substantive application of the regulation, the question arises as to the scope and 
interpretation of the regulation in this case. Even if it transpires that issues 
concerning the application of the regulation are not arbitrable under Swedish 
arbitration law, the limits of the application of the regulation in the present case 
will be relevant to the Svea Court of Appeal in assessing the extent of the possible 
nullity of the arbitration award. 
34 According to the arbitration award, a request for repayment of an advance 
payment related to an agreement whose performance was prevented by Regulation 
833/2014, and the interest claimed in connection therewith, does not constitute a 
claim which is prohibited from being satisfied under Article 11 of Regulation 
833/2014 (see paragraphs 13 and 14 above). The question referred by the Svea 
Court of Appeal in that connection is intended to clarify whether that is a correct 
application of the regulation. 
35 The wording of Article 11 of Regulation No 833/2014 is broad and general. It is 
not possible to draw any firm conclusions about its application with regard to 
repayment and interest on the basis of the wording alone. Nor do the recitals to 
Regulation No 833/2014 provide any specific guidance as to how Article 11 
should be applied in a case such as the present one. 
36 In its review of the lawfulness of Regulation No 833/2014, the General Court 
held, in connection with its proportionality test, that Article 11 ‘is intended to 
prevent an entity targeted by the restrictive measures at issue from being able to 
procure performance of a prohibited transaction, contract or service or from 
obtaining a remedy under civil law for non-performance of such transactions, 
contracts or services’ (see judgment in NK Rosneft, cited above, paragraph 206).  
37 In the context of its review of that judgment, the Court of Justice cited that finding 
of the General Court. In the Court of Justice’s subsequent assessment, the General 
Court had carried out a full proportionality test in relation to Article 11, inter alia 
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by examining the scope and purpose of that article in relation to the appellant’s 
fundamental rights (see the judgment in Rosneft 2, paragraphs 107 and 110 to 
114). 
38 It is therefore with reference thereto that the arbitration tribunal in the present case 
concluded that a request for repayment and interest on the amount repaid does not 
constitute a claim prohibited from being satisfied under Article 11 of Regulation 
833/2014 since the aim of the request is not to perform a prohibited transaction. 
The Svea Court of Appeal agrees that the General Court’s finding gives the 
impression that Article 11 is intended to prohibit claims the aim of which is to 
perform a prohibited transaction, rather than to prevent parties from restoring their 
positions to the situation prior to the conclusion of the agreement. That 
interpretation is also borne out by a comparison with the definition of a claim in 
Regulation No 269/2014, which refers to [performance of] a contract or 
transaction and performance of any obligation. However, in the view of the Svea 
Court of Appeal it is not entirely clear whether the Court of Justice concurred with 
the General Court’s finding regarding the purpose and scope of Article 11 or 
whether it merely found that the General Court had fully assessed the question of 
proportionality. Overall, it is the view of the Svea Court of Appeal that the 
interpretation of Article 11 of Regulation 833/2014 in the present case cannot be 
regarded as having been clarified by the Rosneft judgments. 
39 When applying Article 11 of Regulation 833/2014, guidance can also be sought 
from the application of other sanctions regulations which are standardised and 
reflect the wording of the regulation in question. A prohibition substantially 
similar to that laid down in Article 11 of Regulation 833/2014 is to be found in 
Article 12 of the now repealed Council Regulation (EU) No 204/2011 of 2 March 
2011 concerning restrictive measures in view of the situation in Libya. In a 
preliminary ruling on whether or not, inter alia, a claim arising from a counter 
guarantee agreement can be satisfied under the transaction prohibition, the Court 
of Justice found as follows: 
‘Second, Article 12 of Regulation No 204/2011 prohibits the granting of any 
claim in relation to such a contract or transaction, such as a claim for indemnity, a 
claim for compensation or a claim under a guarantee. By virtue of the general and 
illustrative nature of the list of claims to which it refers, which is introduced by 
the word ‘including’, Article 12 of that regulation encompasses all types of claims 
connected to a contract or transaction.’ (see judgment of the Court of Justice of 
17 January 2019, SH, C-168/17, EU:C:2019:36, paragraph 74; emphasis added) 
40 That suggests that Article 11 of Regulation No 833/2014 must be interpreted 
broadly and in such a way that no claims, including repayment with interest, may 
be granted to actors covered by that regulation where the agreement has been 
subject to restrictive measures under that regulation. 
41 The EU Commission’s answers to questions about Article 11 of Regulation 
833/2014 (Commission Consolidated FAQs on the implementation of Council 
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Regulation No 833/2014 and Council Regulation No 269/2014 of 22 June 2022, 
most recently updated on 5 November 2024) gives the impression, however, that 
that provision, in line with the General Court’s finding regarding the purpose of 
the rule in its judgment in NK Rosneft, only prohibits the granting of claims based 
on damage arising from the application of Regulation 833/2014. The same is 
suggested by the Council’s statements in a document on EU best practices for the 
effective implementation of restrictive measures (document No 11623/24 of 3 July 
2024, paragraph 38), which states that clauses such as Article 11 aim to ensure 
that no person or entity complying with the obligations under the regulation is 
held liable for any damage caused thereby and that the person claiming such 
damages must prove that satisfying the claim for damages is not prohibited. 
Advocate General Paolo Mengozzi, who provides a thorough review of the 
background history of clauses of this type in the EU and the practice of national 
courts in his Opinion in SH, takes a similar line (see points 49 to 53 of the 
Opinion). 
42 As regards, in particular, the issue of interest, the Svea Court of Appeal notes as 
follows. On the one hand, the purpose of interest is to maintain the value of a 
fixed amount over time. It thus seems natural to come to the conclusion reached 
by the arbitration tribunal, provided that repayment is a claim which can be 
satisfied. 
43 On the other hand, according to recital 2 thereof Regulation 833/2014 aims, inter 
alia, to increase the costs of Russia’s actions to undermine Ukraine’s territorial 
integrity, sovereignty and independence. That could militate against granting a 
claim for interest in respect of an otherwise permitted transaction vis-à-vis parties 
subject to restrictions. Even if repayment of an advance payment were acceptable 
under Article 11 of the regulation, it is not clear that interest on the amount is also 
a claim which can be satisfied. 
44 Overall, the Svea Court of Appeal takes the view that it is not clear or clarified 
whether repayment of an advance payment relating a contractual service the 
provision of which is prevented by regulation 833/2014, or interest on such a 
payment, is covered by the prohibition laid down in Article 11 of the regulation.