When an arbitral award is rendered, it becomes enforceable in the territory of all 156 contracting States of the New York Convention. Such States have the obligation to recognize foreign arbitral awards, except when one of the causes for denial set out in the Convention itself takes place, which includes the case of annulment of the award by a competent authority in the seat of arbitration. The annulment may be interpreted as a cause for mandatory denial of recognition and enforcement as well as a mere faculty (to deny) of that State where recognition is requested. A systematic interpretation of the New York Convention – along with national laws and other international treaties – can lead to the recognition (or to the denial of such) of annulled awards in the country where enforcement is sought.
Iurgium [previously Spain Arbitration Review]