| Popis: |
Whether a judicial judgment rendered in one country will be recognized and enforced by the courts of other countries (especially where the judgment debtor might have assets) is a critical question in international litigation. Traditionally, national legal systems have not accepted any binding obligation to recognize or enforce judgments rendered by the courts of other countries. That reality has long posed problems for successful litigants that obtain a judgment against a defendants whose assets are located in a different country. Increasingly, however, states are entering into bilateral arrangements with trusted states and trading partners for this purpose, and in 2019 the Hague Conference concluded the first multilateral “judgments” convention with the potential to transform this area of international civil and commercial practice. This chapter provides an overview of that Convention and a summary of relevant U.S. law and foreign law on enforcement of civil and commercial judgments, as well as arbitral awards. |
