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When a dispute crosses borders, the forum you pick decides everything: how fast you get heard, what it costs, and whether your award is enforceable where the assets sit. Lawyers from nine jurisdictions agree the real test is practical, not abstract, weighing service rules, court speed, court fees, interim relief, public policy and, above all, where you will ultimately enforce. The through-line across Greece, Austria, the UK, Poland, Singapore, Nigeria, Ghana, Zimbabwe and Oman is that an arbitral award under the New York Convention is usually far easier to enforce than a foreign court judgment, which is why clear jurisdiction and arbitration clauses, drafted early, save the most time and money later.
Chapters:
0:00 Introductions: the nine-jurisdiction panel
4:42 Question 1: choosing the forum with competing clauses
4:47 Greece: defendant’s residence and the exceptions
7:05 Austria: enforcement, service speed and court fees
10:27 UK: fair trial concerns and Russian-market cases
12:44 Zimbabwe: convenience, cost and public policy
15:33 Nigeria: permissive versus mandatory clauses, enforcing awards
18:24 Poland: interim relief and freezing assets
19:53 Greece: proving urgency for an injunction
22:26 Austria: security for costs in Russian claims
25:33 Singapore: can we keep the case at home?
26:54 Question 2: challenges enforcing rulings abroad
27:00 UK: a foreign judgment as a basis for bankruptcy
29:45 Ghana: when enforcement reopens the whole case
31:59 Austria: fast recognition with no relitigation
34:19 Nigeria: the 2023 Act and arbitrator immunity
37:49 Poland: motivating enforcement officers
40:03 Zimbabwe: new commercial court rules and public policy
42:20 Greece: refusing to enforce punitive damages
43:30 Question 3: drafting jurisdiction clauses early
43:50 Austria: the cost of pathological arbitration clauses
46:23 Nigeria: governing law and number-of-arbitrators traps
49:11 UK: the case for exploiting ambiguity
51:56 Ghana: certainty, clarity and consistency
53:36 Oman: arbitration over foreign judgments, and close
Panel:
Nikos Christoforidis, Greece
Wojciech Deja, Today Legal, Poland
Ahmed Al Barwani, Barwani Law, Oman
Edward Miller, Madison Legal, United Kingdom
Lim Tat, AQT Legal, Singapore
Katrin Hanschitz, Knoetzl, Austria
Beyeeman Ofori-Atta Akyea, Z Akyea, Ghana
Emokiniovo Dafe-Akpedeye, Compos Mentis, Nigeria
Simon Musapatika, Danziger, Zimbabwe
Hosted by Jenny, Global Law Experts.
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