Enforcement of arbitral awards in United States: overview

A Q&A guide to enforcement of arbitral awards law in United States.

The Q&A gives a structured overview of the key practical issues concerning enforcement of arbitral awards in this jurisdiction, including definitions and preliminary proceedings; applicable conventions; enforcing awards; public policy, enforcement proceedings; formalities; actual enforcement; and any reform proposals.

This Q&A is part of the Enforcement of Judgments and Arbitral Awards in Commercial Matters Global Guide.

Contents

Enforcement of arbitral awards

Definitions and preliminary proceedings

1. What is the definition of an arbitral award in your jurisdiction for the purpose of enforcement proceedings?

An arbitral award is a final judgment or decision by an arbitrator (Black's Law Dictionary, 7th Ed (West 1999)).

 
2. Are decisions in preliminary/provisional proceedings recognised and enforceable?

An arbitral award must be binding on the parties in the foreign country where the award was made in order to be recognised and enforced in the US (Article V(1)(e), UN Convention on the Recognition and Enforcement of Foreign Arbitral Awards 1958 (New York Convention)). The determination of whether a foreign award is final, conclusive and enforceable will be governed by the law of the country where the judgment and award was rendered (S.C. Chimexim SA v Velco Enters. Ltd, 36 F. Supp. 2d 206, 213 (S.D.N.Y. 1999); Dworkin-Cosell Interair Courier Services, Inc v Avraham, 728 F. Supp. 156, 161 (S.D.N.Y. 1989)).

US courts have allowed enforcement of interim injunctive awards that finally and definitively dispose of a separable independent claim, notwithstanding the absence of an award that finally disposes of all the claims that were submitted to arbitration (Island Creek Coal Sales Co v Gainesville, 729 F.2d 1046, 1049 (6th Cir. 1984)). The party seeking confirmation must identify an immediate need for relief to protect the status quo while the underlying claim is still in dispute (Hall Steel Co v Metalloyd Ltd, 492 F. Supp. 2d 715, 719 (E.D. Mich. 2007)). Importantly, US courts have held that an interim order requiring the posting of security to protect a possible final award is a "final" order (Banco de Seguros del Estado v Mut. Marine Offices, Inc, 230 F. Supp. 2d 362, 369 (S.D.N.Y. 2002); Yasuda Fire & Marine Ins Co of Europe v Continental Casualty Co, 37 F.3d 345, 347–48 (7th Cir. 1994)).

Applicable conventions

 
3. What conventions is your jurisdiction a contracting party to?

The recognition and enforcement of foreign arbitral awards in the US is governed principally by the United Nations Convention on the Recognition and Enforcement of Foreign Arbitral Awards (New York Convention). The New York Convention is incorporated into US law through implementing legislation contained in Chapter 2 of the Federal Arbitration Act (FAA) (Title 9, sections 201to 208 US Code). The US is also a party to the Inter-American Convention on International Commercial Arbitration (Panama Convention). The Panama Convention is implemented through legislation codified in Chapter 3 of the FAA (Title 9, sections 301–307, US Code).

Enforcing awards

4. What is the applicable statutory framework for enforcement of awards?
 
5. What are the grounds for refusing enforcement?

Domestic awards

Section 10 of the FAA, lists the grounds for refusing enforcement of arbitration awards, including:

  • Fraud.

  • Evidence of partiality of arbitrators.

  • Arbitrators who have been found guilty of misconduct.

  • Arbitrators exceeding their powers.

International awards

The US has declared that the United Nations Convention on the Recognition and Enforcement of Foreign Arbitral Awards (New York Convention) will only be applicable "to differences arising out of legal relationships whether contractual or not, which are considered commercial under the national law of the state making the declaration"(Title 9, section 202, US Service Code). Generally, this declaration excludes awards arising out of matrimonial or custody disputes, disputes concerning succession to property, labour disputes, and public international law controversies (for example, boundary disputes) (section 487 Restatement (Third) of Foreign Relations Law1987; Island Territory of Curacao v Solitron Devices, Inc, 356 F. Supp. 1, 13 (S.D.N.Y. 1973)).

US courts will refuse to recognise an arbitration award when the award deals with matters not submitted to arbitration or matters beyond the scope of the arbitral agreement, if those matters cannot be separated from the rest of the award (Article V(1)(c), New York Convention). To be successful, the award debtor must overcome a powerful presumption that the arbitral body acted within its arbitral powers (Parsons & Whittemore Overseas Co v Societe Generale de L’Industrie du Papier (RAKTA), 508 F.2d 969, 976 (2d Cir. 1974)).

US courts will not recognise and enforce an arbitral award if the party against whom the award was rendered did not receive proper notice of the proceedings or was otherwise not afforded an opportunity to present its case (Article V(1)(b), New York Convention). This provision incorporates the concept of American due process into the Convention (Parsons & Whittemore Overseas Co v Societe Generale de L’Industrie du Papier (RAKTA), 508 F.2d 969, 975 (2d Cir. 1974)).

US courts will not recognise foreign awards that violate fundamental public policies of:

  • Section 117 of the US Restatement (Second) of Conflict of Laws.

  • Section 4(b) (3) of the Uniform Foreign Money-Judgments Recognition Act 1962(UFMJRA).

  • Section 4(c) (3) of the Uniform Foreign-Country Money Judgments Recognition Act 2005 (UFCMJRA).

  • Article V (2) (b) of the New York Convention.

However this has been narrowly construed, and US courts will deny enforcement based on public policy "only where enforcement would violate the forum state's most basic notions of morality and justice" (Parsons & Whittemore Overseas Co v Societe Generale de L’Industrie du Papier (RAKTA), 508 F.2d 969, 974 (2d Cir. 1974); Somportex, Ltd v Philadelphia Chewing Gum Corp, 453 F.2d 435, 443 (3d Cir. 1971).

 
6. Is the enforcing court required to examine the refusal grounds during the enforcement proceedings ex officio?

A party opposing recognition and enforcement of a foreign arbitral award bears the burden of proving that the award should not be recognised and enforced under the UN Convention on the Recognition and Enforcement of Foreign Arbitral Awards 1958 (New York Convention). However, US courts can raise on its own motion the grounds for non-recognition identified under Article V (2) of the New York Convention that relate to enforcement of public policy and non-arbitrability of the subject matter (see Question 5).

 
7. What is the effect of pending challenge proceedings in the foreign State where the decision is granted?

A US court can stay enforcement proceedings while a challenge is made to the award in the jurisdiction where the award was made.

 
8. What types of arbitral awards are enforceable?

Money awards

US courts generally will recognise and enforce money awards (section 1(2), Uniform Foreign Money-Judgments Recognition Act (UFMJRA); section 3(a)(1), Uniform Foreign-Country Money Judgments Recognition Act 2005 (UFCMJRA); section 481(1), Restatement (Third) of Foreign Relations Law 1987).

Awards containing injunctions ordering or prohibiting the doing of acts

US courts have allowed enforcement of interim injunctive awards that finally and definitively dispose of a separable independent claim, notwithstanding the absence of an award that finally disposes of all the claims that were submitted to arbitration (Island Creek Coal Sales Co v Gainesville, 729 F.2d 1046, 1049 (6th Cir. 1984)). The party seeking confirmation must identify an immediate need for relief to protect the status quo while the underlying claim is still in dispute (Hall Steel Co v Metalloyd Ltd, 492 F. Supp. 2d 715, 719 (E.D. Mich. 2007)). Importantly, US courts have held that an interim order requiring the posting of security to protect a possible final award is a "final" order (Banco de Seguros del Estado v Mut. Marine Offices, Inc, 230 F. Supp. 2d 362, 369 (S.D.N.Y. 2002); Yasuda Fire & Marine Ins Co of Europe v Continental Casualty Co, 37 F.3d 345, 347–48 (7th Cir. 1994)).

Decisions or awards by arbitral tribunals (including emergency arbitrators) granting provisional measures

See above, Awards containing injunctions ordering or prohibiting the doing of acts.

Declaratory awards

Declaratory awards are not generally subject to enforcement, but may be entitled to recognition (section 481, Restatement (Third) of Foreign Relations Law 1974).

Other

See Question 10.

 
9. Can parties seek to enforce only part of the award?

There is no prohibition against partial enforcement.

 
10. Are any class of awards excluded from recognition and enforcement? If so, what types of awards?

The US has declared that the UN Convention on the Recognition and Enforcement of Foreign Arbitral Awards 1958 (New York Convention) is applicable "only to differences arising out of legal relationships whether contractual or not, which are considered commercial under the national law of the state making such declaration"(Title 9, section 202, US Service Code). Generally, this declaration excludes awards arising out of matrimonial or custody disputes, disputes concerning succession to property, labour disputes, and public international law controversies (for example, boundary disputes) (section 487, Restatement (Third) of Foreign Relations Law 1987; Island Territory of Curacao v Solitron Devices, Inc, 356 F. Supp. 1, 13 (S.D.N.Y. 1973)).

 
11. Will service that does not conform to the requirements of international treaties/regulations in force automatically result in a denial of the enforcement of a judgment/award/deed?

US courts must confirm foreign arbitral awards "unless it can prove one of the grounds for refusal" specified in the UN Convention on the Recognition and Enforcement of Foreign Arbitral Awards 1958 (New York Convention) (Title 9, section 207, US Code). Improper service is a discretionary ground for US courts to refuse recognition of a foreign award when the defendant did not receive proper and timely notice of the proceeding (Article V (1)(b), New York Convention).

 
12. What methods of service are not acceptable against defendants domiciled in the State where enforcement is sought?

Service against a defendant located in the US is not acceptable if it does not comply with the HCCH Convention on the Recognition and Enforcement of Foreign Judgments in Civil and Commercial Matters 1971 (Hague Foreign Judgments Convention) or with the Federal Rules of Civil Procedure. A few general examples of unacceptable methods of service are as follows:

  • Service by email.

  • Service on a person lacking capacity to accept service.

  • Service by a person not authorised to effect service.

  • Untimely service.

Public policy

 
13. Which country's public policy applies? Does the court approach the issue differently depending on whether the award is a domestic or international award?

Domestic awards

Whether the award is domestic or foreign, US courts will not recognise awards that violate fundamental public policies of section 117 of the US Restatement (Second) of Conflict of Laws or Article V (2)(b) of the UN Convention on the Recognition and Enforcement of Foreign Arbitral Awards 1958 (New York Convention).This has been narrowly construed, and US courts will deny enforcement based on public policy "only where enforcement would violate the forum state's most basic notions of morality and justice" (Parsons & Whittemore Overseas Co v Societe Generale de L’Industrie du Papier (RAKTA), 508 F.2d 969, 974 (2d Cir. 1974); Somportex, Ltd v Philadelphia Chewing Gum Corp, 453 F.2d 435, 443 (3d Cir. 1971)).

International awards

See above, Domestic awards.

 
14. In which cases and against which awards has the principle of public policy generally been applied?
 

Enforcement proceedings

Procedure

15. What is the procedure for enforcing arbitral awards?

Domestic awards

Formal proceedings must be initiated to enforce arbitral awards. However, the procedures for enforcement provided in the Federal Arbitration Act (FAA) are intended to simplify the process (Title 9, sections 1–16, 201, US Service Code). A party initiates proceedings to confirm an arbitration award by filing either a petition or motion to confirm the award (Title 9, section 6 US Code; Title 9, section 207, US Service Code). The motion or petition can be filed in either US federal or state courts.

To advance the speedy resolution of arbitral proceedings, confirmation of an arbitral award is intended to be summary in nature, and must be initiated and heard through federal motion practice (Title 9 section 6 US Code; Booth v Hume Pub., Inc, 902 F.2d 925, 932 (11th Cir. 1990)). A full hearing in the proceeding may not be required, as a motion to confirm an award can be decided on the papers supported by affidavits, without oral testimony (Booth v Hume Pub., Inc, 902 F.2d 925, 932 (11th Cir. 1990); Parsons & Whittemore Overseas Co v Societe Generale de L’Industrie du Papier (RAKTA), 508 F.2d 969 (2d Cir. 1974)). Confirmation of a foreign arbitral award is characterised as a "summary proceeding" that merely converts what is already a final decision into a judgment of a court (Jiangsu Changlong Chems, Co v Burlington Bio-Medical & Sci. Corp, 399 F. Supp. 2d 165, 168 (E.D.N.Y. 2005)).

Ex parte or on notice. Notice of any filing in a US court seeking recognition and enforcement of a foreign arbitral award must be properly served on the adverse party, and the adverse party must be provided the opportunity to be heard (Fla. Stat. section 55.604; Tex. Civ. Prac. & Rem. Code section 36.0044; La. C.C.P. 2541; Title 9, section 9, US Code).

Applicable court. Federal courts in the US have original jurisdiction to recognise and enforce arbitral awards falling under the UN Convention on the Recognition and Enforcement of Foreign Arbitral Awards 1958 (New York Convention) (Title 9, section 203 US Code). An action brought in state court can be removed to federal court at any time before trial (Title 9, section 205, US Service Code). Generally, venue is proper in any federal court that has personal jurisdiction over the defendant or where the assets are found (Audi NSU Auto Union Aktiengesellschaft v Overseas Motors, Inc, 418 F. Supp. 982, 984 (E.D. Mich. 1976); section 487 Restatement (Third) of Foreign Relations Law 1987).

Limitation period. Enforcement proceedings must be brought within three years of the award (Title 9, section 207, US Code). However, if the award has been reduced to a judgment in a foreign country, state limitations on enforcing foreign judgments may apply.

Timing. The time between filing, confirmation and enforcement of the award can range between several months to over one year.

Court fees. Court fees are not recoverable by either party. The party seeking enforcement will incur filing fees in connection with the petition for confirmation and enforcement of the foreign judgment or arbitral award. The amount of filing fees may vary between federal and state jurisdictions.

Recourse. An appeal can be taken following an order confirming or denying confirmation of an award (Title 9, section 16(a)(1)(D) US Code).

International awards

Confirmation of a foreign arbitral award is characterised as a "summary proceeding" that merely converts what is already a final decision into a judgment of a court (Jiangsu Changlong Chems, Co v Burlington Bio-Medical & Sci. Corp, 399 F. Supp. 2d 165, 168 (E.D.N.Y. 2005)). See above Domestic awards.

Ex parte or on notice. See above Domestic awards.

Applicable court. See above Domestic awards.

Limitation period. See above Domestic awards.

Timing. See above Domestic awards.

Court fees. See above Domestic awards.

Recourse. See above Domestic awards.

 
16. Can the enforcing court review the foreign award if all formalities were complied with and if the award meets all requirements?

If the party seeking enforcement meets all requirements and demonstrates that none of the grounds for non-recognition exist, the court must recognise and enforce the award (Title 9, section 207, US Code; Article V,UN Convention on the Recognition and Enforcement of Foreign Arbitral Awards 1958 (New York Convention)).

Formalities

17. What are the documentary requirements for enforcement?

Documentary requirements

A party seeking recognition and enforcement of an award must supply the court with the (Article IV, UN Convention on the Recognition and Enforcement of Foreign Arbitral Awards 1958 (New York Convention); Geotech Lizenz AG v Evergreen Systems, Inc, 697 F. Supp. 1248, 1252 (E.D.N.Y. 1988)):

  • Duly authenticated original award or a duly certified copy.

  • Original agreement to arbitrate or a certified copy.

  • Duly certified translation of the award (if the award or agreement is in a language different from the official language of the country where the award is to be relied on).

Authentication

An award must be duly authenticated to be recognised in the US (Article IV, New York Convention). The US Federal Rules of Evidence (Fed. Rule of Evid) provide the requirements for authentication of foreign public documents. The award must be signed or attested by a person who is authorised under a foreign country's law. The award must be accompanied by a final certification that certifies the genuineness of the signature and official position of the signer or attester (or of any foreign official whose certificate of genuineness relates to the signature or attestation or is in a chain of certificates of genuineness relating to the signature or attestation). The certification can be made by a secretary of a US embassy or legation; by a consul general, vice consul, or consular agent of the US; or by a diplomatic or consular official of the foreign country assigned or accredited to the US. If all parties have been given a reasonable opportunity to investigate the document's authenticity and accuracy, the court may, for good cause, either order that it be treated as presumptively authentic without final certification, or allow it to be evidenced by an attested summary with or without final certification (Fed. Rule of Evid. 902(3)).

 
18. Is it required to translate the award into the language of the State where enforcement is requested?

Translations

An arbitral award must be translated into English (Article IV, UN Convention on the Recognition and Enforcement of Foreign Arbitral Awards 1958 (New York Convention); Jiangsu Changlong Chems., Co v Burlington Bio-Medical & Sci. Corp, 399 F. Supp. 2d 165, 168 (E.D.N.Y. 2005)).

Other languages

None.

Certification

The translation must be certified by an official or sworn translator or by a diplomatic or consular agent. There is no specific rule governing the nationality of the diplomatic or consular agent who may provide such a certification (Article IV (2), New York Convention).

 
19. What is the format of the application for a declaration of enforceability?

An application for the recognition and enforcement of an award in US federal courts must take the form of a motion requesting recognition of the award, and it must follow the procedures for a motion rather than a new lawsuit (Article IV, UN Convention on the Recognition and Enforcement of Foreign Arbitral Awards 1958 (New York Convention); Imperial Ethiopian Gov’t v Baruch-Foster Corp, 535 F.2d 334, 335 (5th Cir. 1976)).

 
20. What information must be included in the application regarding the award, the claim as awarded in the award, the facts and legal grounds of the case, and that the judgment is no longer appealable?

Award

The motion or petition to confirm the award must contain the identities of the parties, a description of the arbitration agreement, a reference to the arbitration award and a statement of the relief sought.

Claim as awarded

It is not necessary for the claim to be described in detail.

Facts and legal grounds

There is no need to discuss the facts and legal grounds of the award.

Appeals

The motion must state that the award is no longer appealable.

 
21. Is it possible to request the enforcing court for provisional measures pending the enforcement proceedings?

Depending on the court and state in which enforcement is sought, there are procedures for provisional measures pending the enforcement proceedings. For example, under federal or state rules, a judgment creditor may be able to attach assets of the judgment debtor in that jurisdiction pending enforcement proceedings (Rule B, Supplemental Rules for Admiralty or Maritime Claims and Asset Forfeiture Actions).

 
22. Is it required to convert the value of the award into the local currency?

There is no requirement that the foreign award be converted into US dollars, but it would be useful in avoiding complications in enforcement.

 
23. Can the enforcing court stay the enforcement proceedings pending the outcome of proceedings to set aside the award at the seat of arbitration? If so, will the court order the party seeking the stay to provide security?

Article VI of the UN Convention on the Recognition and Enforcement of Foreign Arbitral Awards 1958 (New York Conventions) and Article VI of the Inter-American Convention on International Commercial Arbitration (Panama Convention) allow for the stay of enforcement proceedings, but the court may require security.

 

Actual enforcement

24. What is the enforcement procedure when a declaration of enforceability is granted?

Formal proceedings must be initiated to enforce foreign arbitral awards. However, the procedures for enforcement provided in the Federal Arbitration Act (FAA) are intended to simplify the process (Title 9, sections 1–16, 201 US Code Service). To advance the speedy resolution of arbitral proceedings, confirmation of an arbitral award is intended to be summary in nature, and must be initiated and heard through federal motion practice (Booth v Hume Pub., Inc, 902 F.2d 925, 932 (11th Cir. 1990). A full hearing in the proceeding may not be required, as a motion to confirm an award can be decided on the papers supported by affidavits, without oral testimony (Booth v Hume Pub; Parsons & Whittemore Overseas Co v Societe Generale de L’Industrie du Papier (RAKTA), 508 F.2d 969 (2d Cir. 1974)). Confirmation of a foreign arbitral award is characterised as a "summary proceeding" that merely converts what is already a final decision into a judgment of a court (Jiangsu Changlong Chems, Co v Burlington Bio-Medical & Sci. Corp, 399 F. Supp. 2d 165, 168 (E.D.N.Y. 2005)).

 
25. Can defendants oppose the actual enforcement procedure, and if so, on what grounds/defences?

Once an award has been declared enforceable under a particular state's procedures, it is a judgment and the actual enforcement is subject to the particular laws of that state in which enforcement is being sought as if the judgment was rendered by that state's court. In some states, the judgment creditor is entitled to a lien on real and/or personal property owned by the judgment debtor. Generally, a lien is placed on the property if it is real property. The property is then seized by either US marshals in federal court or local sheriffs for US state jurisdictions and later sold by way of auction. Prior to the sale of any assets, there is typically a notice in advance of a public auction or sale of the property, and the resulting funds are then used to extinguish all or a portion of the judgment (Fla. Stat. sections 56.011 – 56.29; Tex. Civ. Prac. & Rem. Code. sections 34.011 – 34.076; La. C.C.P. 2291 – 2299; 2331 – 2343).

 

Proposals for reform

26. Are any changes to the law currently under consideration or being proposed?

There are no current plans for reform.

 

Online resources

National Conference of Commissioners on Uniform State Laws

W www.uniformlaws.org

Description. The website of the Uniform Law Commission (ULC) states that it has worked for the uniformity of state laws since 1892. It is a non-profit unincorporated association, comprised of state commissions on uniform laws from each state, the District of Columbia, the Commonwealth of Puerto Rico, and the US Virgin Islands. Each jurisdiction determines the method of appointment and the number of commissioners actually appointed. Most jurisdictions provide for their commission by statute.

Uniform Foreign Money-Judgments Recognition Act 1962 (UFMJRA)

W www.uniformlaws.org/Acts.aspx

Description. See above.

Uniform Foreign-Country Money Judgments Recognition Acts 2005 (UFCMJRA)

W www.uniformlaws.org/Act.aspx?title=Foreign-Country%20Money%20Judgments%20Recognition%20Act

Description. See above.

United Nations Commission on International Trade Law

W www.uncitral.org

Description. This is the United Nations website for international conventions.

UN Convention on the Recognition and Enforcement of Foreign Arbitral Awards 1958 (New York Convention)

W www.uncitral.org/uncitral/en/uncitral_texts/arbitration/NYConvention.html

Description. See above.

Organization of American States Foreign Trade Information System (SICE)

W www.sice.oas.org

Description. This website contains information on trade information, policy and legislation.

US Government Publishing Office

W www.gpo.gov

Description. The website contains statutes under the US Code. The information is current.

W www.gpo.gov/fdsys/pkg/USCODE-2011-title9/content-detail.html

Description. The website contains specific statutes under Title 9 of the US Code. The information is current.



Contributor profiles

Antonio J Rodriguez, Partner

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