Recognition and Enforcement of Foreign Judgments: Russia, the European Union and the United Kingdom

This report examines the recognition and enforcement of foreign judgments in civil and commercial matters, focusing on Russia, the European Union and the United Kingdom. It considers the 2019 Hague Judgments Convention, circulation of judgments within the EU, the framework in England and Wales after Brexit, and Russian recognition procedures. Jurisdiction, temporal application, service, public policy and the limits of reconsidering the merits are assessed alongside the practical location and availability of assets. Particular attention is given to sanctions-related disputes, competing claims to exclusive jurisdiction and measures restraining foreign proceedings. The analysis discusses Uraltransmash, UniCredit and developments involving Euroclear, together with restrictions on recognition linked to sanctions. Its central distinction is between recognition of a judgment's legal effects, access to compulsory enforcement and actual recovery. These outcomes may diverge because of immunity, third-party rights, unavailable assets or restrictions on dealings with property.