On 17 June 2026, the First Civil Chamber of the French Cour de cassation (“Court of Cassation”) (English version of decision here) drew an important boundary around enforcement against assets of State-linked entities. The Court accepted the general French-law principle that a creditor of a foreign State may, in certain circumstances, enforce against assets held […]
Enforcement of Arbitration Awards
Blasket v. Spain: Limits on Sovereign Asset Discovery
On 12 June 2026, Judge Beryl A. Howell of the United States District Court for the District of Columbia issued a post-judgment discovery order in Blasket Renewable Investments, LLC v. Kingdom of Spain, a long-running enforcement proceeding arising from an ICSID award against Spain. The decision matters because it confirms both the breadth and the […]
Law 2540/2025: A Significant Expansion of Arbitral Power
Colombia has adopted one of the most ambitious arbitration reforms in recent years. Law 2540/2025 introduces arbitration for enforcement proceedings (arbitraje para procesos ejecutivos), and, in doing so, extends arbitration beyond adjudication into an area traditionally associated with courts. The law’s stated objective is to contribute to the decongestion of the judicial system, but its […]
Devas v. Antrix: Dutch Enforcement and the Limits of Seat-Based Annulment
With the Dutch Supreme Court’s 6 March 2026 dismissal of Antrix’s cassation challenge, attention has once again turned to one of the most closely watched India-linked arbitration disputes in recent years. The dismissal leaves in place the Hague Court of Appeal’s 17 December 2024 judgment in Devas Multimedia America Inc. v. Antrix Corporation Ltd., permitting […]
Import of Sigma Constructores, S.A. v. Republic of Guatemala
The enforcement of arbitral awards against sovereign states in the United States is governed by a carefully structured statutory framework rooted in the New York Convention, and its implementation through Chapter 2 of the Federal Arbitration Act and the Foreign Sovereign Immunities Act of 1976 (FSIA). An arbitral award, although binding, does not automatically carry […]
How Enforcement Works: Turning Arbitral Awards into Real-World Results
As every arbitration practitioner knows, securing a favourable arbitral award is often the culmination of months, or even years, of effort. Parties invest substantial time, money, and energy in arbitration to resolve their disputes. When an arbitral tribunal finally delivers a positive decision, it may feel like the hard work has paid off. Yet, in […]
Compliance with ICSID Awards
Established under the ICSID Convention, ICSID operates independently of local legal systems, providing an autonomous legal framework for dispute resolution. Compliance with ICSID Awards refers to the obligation of parties to adhere to and satisfy the terms of an ICSID award, typically through payment of monetary damages, specific performance, or other remedies ordered by the […]
Recognition, Enforcement and Execution in International Arbitration
Recognition, enforcement and execution in international arbitration are important legal concepts to master as they determine the post-arbitral consequences of an arbitration award once it has been rendered. However, their distinction is often difficult and depends on the legal system in which they are sought. We will review their differences in the following sub-sections. Recognition […]
Asset Tracing in International Arbitration
There is little point in commencing international arbitration proceedings if recovery on the resulting award will be impossible. Hiring an asset tracing firm may help reduce the risk of arbitration proceedings being in vain. Asset tracing involves a thorough examination of financial records, transactions, and other relevant documentation concerning a counterpart. This process may require […]
