After the Paris Court of Appeal annulled the US$14.9 billion Sulu arbitration award on 9 December 2025, Malaysia launched a civil conspiracy action in Jersey against the Sulu claimants, their funders, and lawyers. Image source: original composite image

The Russian tycoon and former Chelsea Football Club owner has returned attention to an island that is also the latest hotbed of the Sulu arbitration by suing the government over the freezing of billions in assets.

The dispute dates back to 2022, when authorities froze his holdings amid inquiries into sanctions violations and potential money laundering. Jersey officials sought documents from Swiss banks, with scrutiny focusing on networks of offshore companies and trusts relocated to Jersey in 2016 and 2017. Authorities allege these organizations were structured to obscure the origins of his wealth and later used to facilitate illicit gains linked to Russia’s invasion of Ukraine. It is contended that billions of dollars moved through opaque vehicles, highlighting how Jersey’s regulatory gaps can enable coordinated schemes to conceal and protect assets from oversight.

This pattern is far from unique. Leaked documents from the so-called La Hougue files revealed that Kevin and Ian Maxwell, brothers of infamous convicted sex offender Ghislaine Maxwell, executed secretive trades and related-party transactions that moved millions of dollars through opaque entities in Jersey.

“Leaked documents revealed that convicted sex offender Ghislaine Maxwell’s brothers moved millions of dollars through opaque entities in Jersey.”

Nerve center of the Sulu Conspiracy

This context exposes why the Sulu claimants’ multi-jurisdictional campaign would use Jersey as its financial nerve center to fund its coordinated conspiracy to seize the assets of Malaysia. The Channel Island represents a regulatory framework combined with a jurisdictional separation from the rest of the UK and the EU, shielding transactions from scrutiny and creating an ideal hub for wealthy individuals like Abramovich as well as the secretive machinery behind the Sulu arbitration.

“The Channel Island represents a regulatory framework combined with a jurisdictional separation from the rest of the UK and the EU, creating an ideal hub for wealthy individuals like Abramovich as well as the secretive machinery behind the Sulu arbitration.”

Eight individuals claiming descent from the Sultanate of Sulu sought nearly $15 billion through arbitration overseen by Spanish arbitrator Gonzalo Stampa. On December 9, 2025, the Paris Court of Appeal annulled the award, a final court defeat for the arbitration after Stampa and the claimants attempted to enforce it across Spain, France, Luxembourg, and the Netherlands.

The operation, an instance of “forum shopping” to bypass Spanish court rulings, was costly with a presumably significant paper trail, returning attention to Jersey, the suspected point of financial origin and where the Sulu claimants, their British and Spanish lawyers, and their litigation funder Therium face allegations of unlawful means conspiracy.

Civil law defines this as coordinated action to achieve financial gain through unlawful acts that cause loss to others. The repeated attempts to fund efforts to seize billions in defiance of court orders demonstrate a systematic exploitation of Jersey’s permissive regulatory environment. Indeed, Therium’s Jersey cells have been accused by industry insiders of operating without rigorous client vetting, a critical factor given that Muhammad Fuad Abdullah Kiram, the head of the Sulu claimants, has been designated a terrorist by Malaysia for links to militants involved in the 2013 Lahad Datu invasion. Kiram also maintains ties to the MNLF, a group only recently distanced from decades of militant activity in Mindanao.

“Therium’s Jersey cells have been accused by industry insiders of operating without rigorous client vetting, a critical factor given that Muhammad Fuad Abdullah Kiram has been designated a terrorist.”

The arbitration campaign spans multiple countries and layers of influence. Former arbitrator Gonzalo Stampa, who was ethically bound to remain neutral while presiding over the Sulu arbitration, maintained close ties to Sulu claimants’ lawyers at B. Cremades and Associates.

What’s more, signs suggest the claimants’ push was supported by behind-the-scenes influence specialists, alongside a coordinated legal and information effort. That puts Therium’s role as funder in a harsher light—and raises questions about what exactly its money helped set in motion and whether it underwrote tactics that wouldn’t stand up to scrutiny.

Will Jersey act?

Jersey remains a “wild west” jurisdiction, where both private actors and public officials can operate behind a veneer of legality. Efforts by the government to investigate questionable flows linked to Abramovich have themselves sparked accusations of misconduct, with Abramovich alleging a conspiracy by Jersey authorities. A recent judgment ordered the government to pay his legal costs, describing its failure to produce requested documents for more than two years as “extreme.” The case highlights how Jersey’s permissive environment enables wrongdoing to circulate freely, allowing both public and private actors to exploit regulatory gaps while avoiding accountability.

“Abramovich’s case highlights how Jersey’s permissive environment enables wrongdoing to circulate freely, allowing both public and private actors to exploit regulatory gaps while avoiding accountability.”

The case highlights how Jersey’s permissive environment enables wrongdoing to circulate freely, allowing both public and private actors to exploit regulatory gaps while avoiding accountability.

In this environment, whether justice will be achieved in the Sulu claimants’ conspiracy remains a moral and reputational choice facing Jersey’s Royal Court. The government faces an urgent question: will it enforce the law consistently, or continue to apply it selectively to high-profile targets while allowing other actors to finance attempts to seize billions from nations distant from Europe yet no less deserving of sovereignty?

“Will Jersey enforce the law consistently, or continue to apply it selectively to high-profile targets while allowing other actors to finance attempts to seize billions from nations distant from Europe yet no less deserving of sovereignty?”

For now, Therium’s financing of the Sulu campaign has become notorious, but details of how precisely the money was spent remain largely hidden behind the doors of the Channel Island. It’s the center of these parallel stories, simultaneously hosting the Sulu claimants’ paper trail, facilitating ongoing disputes over Russian oligarchic wealth, and shielding financial activity tied to historically notorious figures like the Maxwell family.

These intersecting cases reveal a stark reality: Jersey’s legal and financial framework not only allows secrecy but also creates fertile ground for manipulation and complex schemes that can span multiple jurisdictions. Despite its reputation as a stable and discreet financial center, the island’s regulatory gaps make it a stage where wealth and influence routinely outpace oversight, raising urgent questions about the limits of accountability and the risks posed to the integrity of global finance.

REFERENCES

Goodley, S (2025, November 16). Roman Abramovich makes claim of “conspiracy” against Jersey government. The Guardian. https://www.theguardian.com/

ITV. (2025, November 20). Why Roman Abramovich is suing the Government of Jersey over £5 billion of seized assets. ITV. https://www.itv.com/

KnowSulu. (2025, November 11). Corrupt arbitration? Questions grow over Stampa’s ties to Sulu claimants’ lawyers in Spain. https://knowsulu.ph/

KnowSulu (2025, December 12). Jersey court greenlights counterclaims against Sulu heirs and funders. https://knowsulu.ph/