Key takeaways

• Three recent judgments refusing to enforce annulled arbitral awards continue U.S. courts’ focus on the associated foreign court judgments.
• Both the D.C. and Second Circuit courts granted comity to foreign courts’ annulment decisions, while the New York state appellate court denied comity to a foreign court’s recognition of an annulled award.
• The New York state court even went one step further and enjoined a party from taking steps to enforce the annulled award abroad. This appears to be the first time that a New York court has restrained enforcement of an arbitral award abroad.