Enforcing a Money Judgment Abroad - The SIFoCC Memorandum

Jane Lambert

I am grateful to Mark Beer for bringing the Standing International Forum of Commercial Courts ("SIFoCC") and its Multilateral Memorandum on Enforcement to my attention in a post on Linkedin.  Mark is now President of the International Association for Court Administration.  I first heard of him when he was Chief Executive of the English speaking common law courts in Dubai known as the Dubai International Financial Centre Courts which I first discussed in DIFC Courts on 7 Jan 2011 JDSupra.

SIFoCC was established at a meeting in London of judges of many of the world's commercial courts convened by Lord Thomas (former Lord Chief Justice of England and Wales) in May 2017  (see History of SIFoCC).  Its members include the Business and Property of Courts of England and Wales (see Jane Lambert Launch of a Judicial Superhighway 12 July 2017 IP Northwest), the Court of Session in Scotland, the High `Court of Northern Ireland, the US District Court for the Southern District of New York, the Supreme Court of New York, the Paris Commercial Court, the Netherlands Commercial Court, the Hamburg Landgericht, the Supreme Peoples' Court of the Peoples' Republic of China, the Supreme Court of Japan, the Supreme Court of Singapore and the English speaking common law courts in Abu Dhabi, Dubai, Kazakhstan and Qatar,

At its inaugural meeting, SIFoCC set itself a number of tasks one of which was to compile a multilateral memorandum on current best means of enforcing commercial judgments between members.  It accomplished that task on 24 June 2019 with the publication of the Memorandum (see the announcement Multilateral Memorandum on Enforcement 24 June 2019).  The document covers the following jurisdictions:

• Abu Dhabi - Abu Dhabi Global Market Courts
• Australia - Federal, New South Wales and Victoria 
• Bahrain,
• Bermuda
• Canada
• Cayman Islands
• China,
• Dubai
• Eastern Caribbean
• France
• The Gambia
• Germany
• Ghana
• Hong Kong
• Republic of Ireland
• Kazakhstan – Astana International Financial Centre Court
• Malaysia
• The Netherlands
• New Zealand
• Nigeria
• The Philippines
• Qatar – Qatar International Court
• Sierra Leone
• Singapore
• Sri Lanka
• Uganda
• UK - England and Wales, Scotland and Northern Ireland
• The USA - Delaware. New York and Pennsylvania.

Anyone wishing to discuss this article or enforcing judgments abroad should call me on 020 7404 5252 during office hours or send me a message through my contact form.