In Spain, this requires proceedings to recognise the foreign arbitral award (following the provisions of the New York Convention) before it can be enforced. Thus the losing party may have time to take measures to frustrate or hinder the enforcement proceedings.
In order to tackle this problem, it is possible to ask for interim measures that remain in place while the recognition proceedings are ongoing.
This article first appeared in the March 2022 Arbitration Committee bulletin of the International Bar Association, and is reproduced by kind permission of the International Bar Association London, UK. International Bar Association.
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