International Arbitral Award Enforcement

China’s accession to the New York Convention, with both the commercial and reciprocity reservations, provides a robust framework for enforcing foreign arbitral awards. Our practice covers:

Pre-Filing Strategy

• Assessment of the award’s enforceability under the New York Convention
• Analysis of potential Article V refusal grounds
• Identification of the competent intermediate people’s court
• Asset investigation to identify enforcement targets

Application and Proceedings

• Preparation of the enforcement application with required documentation
• Submission of the authenticated arbitration agreement and award
• Certified Chinese translation of all foreign-language materials
• Representation at court hearings and supplemental submissions

Resisting Refusal Grounds

• Countering arguments on arbitrability under Chinese law
• Defending the integrity of the arbitral process
• Public policy analysis — distinguishing mandatory rules from genuine public policy
• Addressing scope-of-arbitration-agreement challenges

Execution

• Obtaining the enforcement order (执行裁定书)
• Coordinated execution strategy targeting bank accounts, real property, and equity interests
• Negotiating settlement where strategic