On 17 June 2026, the First Civil Chamber of the French Cour de cassation (“Court of Cassation”) (English version of decision here) drew an important boundary around enforcement against assets of State-linked entities. The Court accepted the general French-law principle that a creditor of a foreign State may, in certain circumstances, enforce against assets held […]
Blasket v. Spain: Limits on Sovereign Asset Discovery
On 12 June 2026, Judge Beryl A. Howell of the United States District Court for the District of Columbia issued a post-judgment discovery order in Blasket Renewable Investments, LLC v. Kingdom of Spain, a long-running enforcement proceeding arising from an ICSID award against Spain. The decision matters because it confirms both the breadth and the […]
State Immunity and ICSID Awards: The UK Supreme Court Joins International Consensus on Enforcement
On 4 March 2026, the Supreme Court of the United Kingdom (the “Supreme Court”) held in Kingdom of Spain v Infrastructure Services Luxembourg S.À.R.L. and Republic of Zimbabwe v Border Timbers Ltd that Spain and Zimbabwe (the “States”) could not invoke state immunity to resist the registration in England of ICSID awards rendered against them. The […]
Devas v. Antrix: Dutch Enforcement and the Limits of Seat-Based Annulment
With the Dutch Supreme Court’s 6 March 2026 dismissal of Antrix’s cassation challenge, attention has once again turned to one of the most closely watched India-linked arbitration disputes in recent years. The dismissal leaves in place the Hague Court of Appeal’s 17 December 2024 judgment in Devas Multimedia America Inc. v. Antrix Corporation Ltd., permitting […]
Import of Sigma Constructores, S.A. v. Republic of Guatemala
The enforcement of arbitral awards against sovereign states in the United States is governed by a carefully structured statutory framework rooted in the New York Convention, and its implementation through Chapter 2 of the Federal Arbitration Act and the Foreign Sovereign Immunities Act of 1976 (FSIA). An arbitral award, although binding, does not automatically carry […]