Reciprocity Strategy & Treaty Analysis

Understanding the legal basis for enforcement is the first and most critical step. Our practice provides:

Treaty-Based Enforcement

• Analysis of bilateral judicial assistance treaties between China and 39 countries
• Interpretation of treaty provisions on recognition and enforcement of civil and commercial judgments
• Assessment of treaty exclusions (tax, customs, administrative matters)
• Guidance on treaty-specific procedural requirements

Reciprocity-Based Enforcement

• Tracking the evolving reciprocity jurisprudence of Chinese courts
• Analysis of the “presumptive reciprocity” framework (推定互惠) adopted in recent years
• Identification of foreign court decisions recognizing Chinese judgments — a key element of reciprocity
• Assessment of reciprocity prospects for specific jurisdictions

Jurisdictional Analysis

• Country-specific enforceability assessments
• Identifying the optimal Chinese court for filing based on debtor location, asset location, and local court practice
• Evaluating the “appropriate connection” (适当联系) standard for jurisdiction

Pre-Filing Legal Opinions

• Written opinions for foreign counsel on enforcement prospects
• Analysis of specific risks (public policy, due process, service, finality)
• Cost and timeline estimates for client decision-making