Enforcement Of International Arbitration Awards In Russia

Foreign arbitration awards are recognized and enforced in Russia by virtue of international treaties to which Russia is an assignee or according to the principle of reciprocity. Since the vast majority of countries have joined the New York Convention, the most common way to enforce a foreign award in Russia is under the said convention.

The Russian Arbitration Code provides for application for recognition and enforcement of a foreign arbitration award to be filed with an arbitrage court at the place of the debtor’s domicile or, if unknown, at the place where the debtor’s assets are located. Unfortunately, the law does not clarify what to do if the debtor’s domicile is abroad. If such is the case, in some instances courts have denied enforcement because the law does not stipulate which court has jurisdiction.