U.S. Refusal to Enforce Intra-EU Arbitral Award Set Aside in Sweden
A U.S. District Court in Washington, DC has ruled that an intra-EU arbitral award set aside in Sweden cannot be enforced in the United States, affirming that annulled awards face significant hurdles. It aligns with the practice of US courts to generally defer to the annulment decisions of the courts at the seat of arbitration. Specifically, it reflects a cautious approach by US courts towards annulled intra-EU awards, signaling that annulled intra-EU awards cannot bypass EU annulment decisions by seeking enforcement in the United States.