I. Introduction

The enforcement of foreign judgments depends on the legal regime applicable to the case. In common law jurisdictions, enforcement may proceed, depending on the circumstances, either by registration under a statutory regime (whether based on reciprocal arrangements or international conventions) or by an action on the foreign judgment at common law. In civil law jurisdictions, enforcement generally requires exequatur proceedings, which may be governed by domestic law or, where applicable, by an international convention. Where an international convention applies, its provisions should, in principle, govern the enforcement process, unless the convention itself provides otherwise or leaves a particular matter to be governed by domestic law.

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