When an arbitral award is not fulfilled by its debtor, its creditor can execute it in any country where his debtor has property. But, in order to enforce it, the award must be recognized by the foreign country.Most probably, those proceedings will be governed by the 1958 United Nations Convention. According with its article V, the award debtor has seven arguments to oppose the recognition. That is the entire defense he has. Besides commenting on those arguments, this article argues that there is an implied condition in the Convention which fulfillment cannot be avoided by the party that opposes the recognition of the award.
Iurgium [previously Spain Arbitration Review]