In anticipation of the awaited decision of the Court of Appeal in Fiona Trust v Privalov ([2016] EWHC 2163 (Comm)), we take a look at the Court’s approach to awarding damages under the usual cross-undertaking given by an applicant for a Freezing Order. The undertaking is not to be taken lightly and it has proved to be a serious obligation potentially leading to a significant liability.

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