Abstract

International commercial arbitration ultimately depends on national courts at the enforcement stage, where the pro-enforcement bias of the New York Convention must be reconciled with the forum's mandatory public policy. Although Article V(2)(b) permits refusal of recognition or enforcement on public policy grounds, it is intended to operate as a narrow and exceptional safeguard. The rapid expansion of sanctions regimes, particularly in the European Union and the United Kingdom, has placed increasing pressure on this framework, as award debtors argue that sanctions compliance ...