Recognition and Enforcement of Foreign Arbitral Awards Under Russian and US Law

The work is devoted to recognition and enforcement of foreign arbitral awards in the Russian Federation and the USA – the countries with different legal systems, which as a result influences the diversity of procedures. Basis of the work is formed with the sources of the recognition and enforcement of foreign arbitral awards, the primary one is the New York Convention on the Recognition and Enforcement of Foreign Arbitral awards 1958, the importance of which is undoubted. Moreover, we have analyzed national sources, meaning the procedural legislation of the country, where recognition and enforcement is sought. Within the framework of the present work we have also analyzed the procedural background of the recognition and enforcement in conjunction between the jurisdictions; besides, the considerable part of the work is devoted to the grounds for refusal of the recognition and enforcement of foreign arbitral awards, limited by the New York Convention 1958 (the same grounds are envisaged by the national legislation). What is more, we have paid attention to the alternative procedures, which can be claimed at the stage of the recognition and enforcement of foreign arbitral awards (for example, set-off defense).