Beneathco DMCC v RJ O’Brien Limited

RJOL was not contractually obliged to comply with Beneathco's instructions for payment in AED or to third parties; RJOL's obligation was limited to paying Beneathco in USD as held. Even if RJOL were otherwise obliged, the Ralli Bros principle suspended performance due to US sanctions prohibiting payment via US correspondent banks. The UK Blocking Regulation did not override this suspension as the relevant US law was not extraterritorial for the acts in question.

Parties: Claimant: Beneathco DMCC; Defendant: R. J. O'Brien Limited
Jurisdiction: England and Wales
Judgment Date: 24 November 2025
Procedural Posture: Commercial Claim / Final Judgment After Trial
Outcome: Claim dismissed
Legal Topics: Implied Terms, Trusts Over Client Funds, International Sanctions, Ralli Bros Principle, Blocking Regulation, Specific Performance, Damages

Contract Law Trust Law Sanctions Law Implied Terms Trusts Over Client Funds International Sanctions Ralli Bros Principle Blocking Regulation +2 more

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Parties

Beneathco DMCC

Claimant

R. J. O'Brien Limited

Defendant

Procedural Posture

Commercial Claim / Final Judgment After Trial

Legal Issues

1 Whether RJOL was contractually obliged to comply with Beneathco's instructions to pay out client funds
2 Whether RJOL's obligation was suspended by the Ralli Bros principle due to US sanctions
3 Whether RJOL owed a debt or held funds on trust for Beneathco

Ratio Decidendi

Court Disposition

Claim dismissed