Collecting Foreign Judgments Against US Entities

Enforcing international arbitration awards in foreign jurisdictions has long been a staple of international business. Indeed, the practice is so common that it's governed by an international treaty. The so-called New York Convention was adopted by the United Nations in 1958 and has been ratified by virtually every industrial country in the World, guaranteeing enforceability of foreign arbitration awards as a matter of reciprocity.

Less well known is the manner of enforcing foreign law judgments. Judgments of foreign courts can be enforced against US entities (citizens and corporations) in US courts with relative ease as well. US enforcement can proceed under the Uniform Foreign Money Judgments Recognition Act ("the Model Act"). The main requirements are that the foreign judgment be final and for a sum of money, and that the defendant had an opportunity to defend itself.