Enforcing international arbitral awards

Introduction to recognition and enforcement of international arbitral awards

Practice Note: Recognition and enforcement of international arbitral awards—an introduction provides an introduction to some of the key issues for practitioners regarding the recognition and enforcement of international arbitration awards. It discusses: some of the considerations for award creditors post-award; where to seek enforcement, including locating the award debtor’s assets; and, the options for recognition and enforcement before domestic courts (including exequatur).

See also: State immunity and arbitration—overview.

The New York Convention

This Practice Note gives information about the Convention on the Recognition and Enforcement of Foreign Arbitral Awards (the New York Convention), including how to make an application for recognition or enforcement of an arbitral award under the New York Convention and the limited grounds on which such an application to enforce a New York Convention award can be refused. It discusses the reciprocity and commercial reservations to the New York Convention.

For more information, see Practice Note: The New York Convention—the recognition and enforcement of arbitral awards—an introduction.

Settlement in arbitration

This Practice Note covers issues surrounding settlement in arbitration,

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Who decides what? Clarifying the boundaries of Appellate Control over Exequatur in France(France – Federative Republic of Brazil (União) v [J])

Arbitration analysis: On 8 January 2026, the Paris Court of Appeal, sitting through the conseiller de la mise en état, held that it lacked jurisdiction to determine the admissibility of a plea seeking annulment of an exequatur order on the basis of an alleged excess of power of the first-instance judge. According to the court, such a plea concerns the appeal itself and therefore falls within the jurisdiction of the Court of Appeal sitting as a full bench, rather than that of the conseiller de la mise en état acting alone. The order was made in proceedings concerning the exequatur in France of a partial award rendered in São Paulo under the auspices of the Câmara de Arbitragem do Mercado (CAM), in a shareholder dispute between minority shareholders of Petrobras and the Federative Republic of Brazil (the União). Although the ruling addresses a strictly procedural issue, it usefully clarifies the allocation of functions between the pre-trial judge (conseiller de la mise en état) and the appellate bench in proceedings brought against exequatur orders under article 1527 of the French Code of Civil Procedure. It confirms that a procedural argument seeking to invalidate the appeal (fin de non-recevoir), where that argument is in fact tied to the substance of the appeal itself, must be decided by the full bench and cannot be filtered out by a single judge at the pre-trial stage. The ruling therefore has practical implications for how parties should frame and time their procedural arguments in exequatur-related appeals. Written by Marie-Laure Cartier and Alexandre Meyniel, partners at Cartier Meyniel AARPI with Sami Kabbara, trainee lawyer at the Paris Bar Centre and intern at Cartier Meyniel AARPI.

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