Emerging Trends of Recognition and Enforcement of Foreign Judgments and Arbitral Awards Issued in Economic Disputes in the Russian Federation

Abstract

International trade includes a procedural dimension, in particular access to courts and mutual recognition and enforcement of foreign judgments and arbitral awards. The author discusses topical issues in this field from the perspective of Russian law, which is often used as a comparative model in other countries of the Caucasus-Central Asian region. The contribution states that Russian courts show a somewhat cautious attitude towards recognition of foreign judgments (much less towards foreign arbitral awards), but cannot be described as principally negative in this respect. The article then addresses the topics of reciprocity as a sufficient reason for recognition (open question), the relationship between exclusive jurisdiction and arbitrability (denied), the requirement of due notice to defendants and public policy (use decreasing).