Recognition and Enforcement of Foreign Court and Arbitration Decisions in Russia and Turkey

A Practical Guide for European Clients (2025)
(Russia-Turkey Legal Alliance – RT Union)

In today’s global business environment, obtaining a court or arbitral award is only the first step. The real challenge lies in making that award enforceable where the debtor’s assets are located.

For European companies and investors dealing with counterparties in Russia or Turkey, the ability to enforce judgments or awards in these jurisdictions is critical.

RT Union provides end-to-end support for the recognition and enforcement of decisions issued by courts and arbitral tribunals in the European Union, the UK, Switzerland, and other major European jurisdictions in both Russia and Turkey.

1. Enforcement of European Judgments and Awards in Turkey

Turkey is a party to the New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards (1958) and applies the provisions of Law No. 5718 (MÖHUK) for the recognition and enforcement of foreign court judgments.

Key requirements for successful enforcement in Turkey (2025)

The decision must be final and binding.
Reciprocity exists between Turkey and the country of origin (in practice, judgments from most EU countries, the UK, and Switzerland are routinely recognized).
The dispute must not fall under the exclusive jurisdiction of Turkish courts (e.g., Turkish real estate matters).
The decision must not violate Turkish public policy.

Procedure

An exequatur application is filed with the competent Turkish Civil Court of First Instance. The process is adversarial; the Turkish court may review the merits to a limited extent and can request the original case file.

With proper preparation, recognition is usually granted within 8–18 months.

Practical advantages for European clients

Turkey has a well-established practice of enforcing EU and UK judgments.
Enforcement against bank accounts and movable assets is fast and effective once the exequatur is issued.

2.Enforcement of European Judgments and Awards in Russia

Russia is also a party to the New York Convention. Recognition and enforcement of foreign court judgments are governed by Articles 409–416 of the Civil Procedure Code (for general courts) and Articles 241–246 of the Commercial Procedure Code (for arbitral awards and commercial disputes).

Key Requirements in Russia (2025)

The decision must be final and enforceable in its country of origin.
Reciprocity exists. In practice, judgments from EU Member States, the UK, and Switzerland are recognized and enforced without significant issues due to long-standing judicial practice.
The dispute must not fall under Russia’s exclusive jurisdiction.
The decision must not contravene Russian public policy.

Procedure

An application for recognition and enforcement is submitted to the competent Russian court (district court or arbitration court) at the debtor’s place of residence or where assets are located. The process is adversarial, but with proper documentation (apostille, certified Russian translation, proof of proper service), recognition is typically granted within 3–8 months.

Practical Advantages for European Clients

Russian bailiffs (FSSP) act swiftly once enforcement is approved. Bank accounts are blocked within days, and asset sales are efficient.

Russian courts have a high success rate for EU and UK judgments when procedural requirements are met.

Recommended Strategy for European Clients

Draft the European judgment or award with enforcement in Russia and Turkey in mind
Ensure proper service of process (Hague Service Convention or other methods).
Avoid excessive punitive damages or interest rates that could be challenged on public policy grounds.
Obtain apostille and certified translations into Turkish and Russian.
Consider pre-enforcement mediation or negotiation in Russia and Turkey
A formal mediation attempt in the target country demonstrates good faith and strengthens your position.
File for recognition and enforcement through experienced local counsel
RT Union handles the entire process with lawyers admitted to the bars of Russia, Turkey, and several European jurisdictions.

Why Choose RT Union?

Dual-qualified lawyers in Russia, Turkey, and Europe.
Hundreds of successfully enforced European judgments and awards in both jurisdictions.
Full-service approach: from drafting the original claim to receiving payment.
Transparent fees and no hidden costs.

Pavel Chukavin

Head of International Practice

Russia-Turkey Legal Alliance – RT Union

Istanbul – Moscow – Europe