The enforcement of the foreign arbitral awards in Turkish and Russian Law

The enforcement of the foreign arbitral awards in the international domain are bound to international and national acts of law. Both in Turkish and Russian judicial systems, it?s agreed that international treaties are superior to national acts of law in the implementation lineage. In our master?s thesis, the enforcement of the foreign arbitral awards in Turkish and Russian judicial systems has been studied within the framework of international treaties which embody the enforcement of the arbitral awards.In the first part of our study, the properties of the international trade arbitrage are examined with the aid of general knowledge about national and international arbitrage and then compared with the alternate resolutions to the disputes. In the second part of our thesis, international treaties which embody the enforcement of the foreign arbitral awards and the enforcement of the foreign arbitral awards in Turkish judicial system have been studied.In Turkish judicial system, the enforcement of the foreign arbitral awards is implemented according to the provisions of the 1958 New York Convention. Therefore, in our thesis, we are specifically focused on the provisions of the 5. th article of New York Convention which embodies the grounds for the refusal of the demand for the enforcement of the foreign arbitral awards. The enforcement of the foreign arbitral awards which are not covered by New York Convention is subject to International Private and Procedure Law. The regulation of this law regarding the enforcement of the arbitral awards and the international treaties of which Turkey is a side have been studied at the end of the second part.The enforcement of the arbitral awards in the Russian Law has been studied in the third part. In this section, a short history of arbitration in Russia and information on the regulations regarding the national and international arbitration are presented. As we concluded that the enforcement of the arbitral awards in Russia is subject to international treaties and that Russian Law Legislation is in accordance with the afore mentioned international regulations, then we presented some samples of the judicial decisions regarding the enforcement of the arbitral awards. At the end of this section international treaties of which Russia is a side have been examined.At the conclusion part of our thesis, Turkish Law and Russian Law have been compared then similarities and differences have been presented.Key Words: International Arbitration, Arbitral Awards, New York Convention, Turkish Law, Russian Law.