Following a long and somewhat sleepy existence on the margins of contractual interpretation case law, force majeure clauses (“FMCs”)  found themselves subject to a rude awakening with the global onset of COVID in 2020, and consequent interruptions to all manner of contracts relating to global supply chains, major sporting events, and many other facets of business. The judicial analysis of how and when FMCs are engaged in international commerce has continued post-COVID, with the introduction of wide-ranging Sanctions against Russia.