EUROPEAN U-TURN IN REGULATION OF RECOGNITION AND ENFORCEMENT OF FOREIGN JUDGMENTS AND FOREIGN ARBITRAL AWARDS IN THE RUSSIAN FEDERATION
The subject of this article is a comparative analysis of the legal regulation of recognition and enforcement of foreign judgements and arbitral awards in countries of Western Europe and Russia. The goal is to identify current trends in reforming institutions and court’s decision-making, to define the limits of the international principles of “courtesy” and “reciprocity” in the balance of public and private interests as well as to embody European procedural standards for harmonizing domestic legislation. Research rationale is inferred due to the increasing role of international regulations and soft norms in the area of recognition and enforcement of foreign judgements and arbitral awards. The empirical field includes approaches to the recognition and enforcement of foreign judgments of four countries: Russia, Germany, France and the United Kingdom. In conclusion, we made proposals regarding the reform of domestic legislation based on prescriptions. The field of approbation of the results is the Committee of the State Duma on civil, criminal, arbitration and procedural legislation, courts of general jurisdiction and arbitration courts of the Russian Federation.