Yukos universal limited (isle of man) v the Russian federation enforcement of the yukos awards: a second noga saga or a new sedelmayer fight?

fouret, julien and daureu, pierre;

A party faced with a Convention award against him has two options. Firstly he can apply to the courts of the country where the award was made to seek the setting aside of the award. If the award is set aside then this becomes a ground in itself for opposing enforcement under the Convention. Secondly, the unsuccessful party can decide to take
no steps to set aside the award but wait until enforcement is sought and attempt to establish a Convention ground of opposition