I. Introduction
Foreign judgment enforcement in Turkey is the practical gateway for a creditor holding a judgment or arbitral award obtained abroad, and recovering the underlying commercial debt in Turkey is rarely a matter of a single action. However firm the decision, it cannot be taken straight to enforcement in Turkey. Collecting the debt requires the decision first to be enforced (tenfiz) under the Act on Private International and Procedural Law, and then pursued through execution under the Enforcement and Bankruptcy Law.
For foreign judgment enforcement in Turkey, recovery on a foreign decision should be seen as two distinct stages, making the decision enforceable in Turkey, and then actually collecting the debt. That said, the time between those two stages matters can be equally important as the stages themselves. While foreign judgment enforcement in Turkey is pending, a debtor who disposes of assets can render the decision worthless. The success of the recovery therefore