Draft: this English version is pending final review.
Enforcement and assets
Enforcing Russian judgments and arbitral awards in Israel
The debtor holds assets in Israel and you hold a Russian judgment or award. To reach those assets, the judgment must be declared enforceable by an Israeli court. The outcome turns on how Russian law is proved to that court.
01Who it is for
Typical clients
- Russian banks and companies holding a judgment against a debtor with assets in Israel
- Award creditors under ICAC (Moscow) awards and other Russia-seated arbitrations
- Russian insolvency officeholders tracing a debtor’s assets abroad
- Israeli lawyers who need a Russian-law expert or co-counsel in such a case
02Typical situations
What we see
The debtor has moved to Israel
The judgment is final in Russia, enforcement there has produced nothing, and the debtor’s property, accounts or shares are in Israel.
Reciprocity is denied
The debtor argues that Russia does not enforce Israeli judgments and asks the court to dismiss under section 4 of the Foreign Judgments Enforcement Law.
The judgment rests on a criminal conviction
Damages were awarded in criminal proceedings, or the civil court relied on the conviction. The debtor pleads public policy.
An award without a writ of execution
The debtor claims an ICAC award is not final until a Russian state court has issued a writ of execution.
Time is running
As a rule the application must be filed within five years of the judgment. After that, special reasons are required.
03What we do
How the work is structured
Assessment
The judgment is tested against the Israeli statutory conditions: jurisdiction, finality, enforceability in Russia, time limits and likely defences.
Opinion
An expert opinion on Russian law covering reciprocity, finality and enforcement procedure, with a Hebrew translation.
Application and interim relief
The application to declare the judgment enforceable is filed. Where dissipation is a risk, interim relief is sought in parallel.
Execution
Once declared enforceable, the judgment moves to the Execution Office: attachments, restrictions and realisation of assets.
04The role of Russian law
Why the case cannot be won without an opinion
An Israeli court treats foreign law as a matter of fact. Its content is proved by an expert opinion, and the expert is cross-examined on it.
In Russian-judgment cases three questions depend on the expert: whether there is a “reasonable potential” for Israeli judgments to be enforced in Russia; whether the judgment is final and enforceable under Russian rules; and whether the defendant’s procedural rights were respected.
Courts expressly note when a party criticises the Russian system without filing an opinion of its own: such arguments remain unproven.
If the case is already run by your firm, I can act as expert only: opinion, translation and examination.
For lawyers and banks06Questions and answers
There is no treaty between Russia and Israel on enforcement of judgments. Is that a bar?
Can assets be frozen before the enforcement case ends?
Does the expert have to travel to Israel?
07Request a case assessment
Request a case assessment
A reply within 1–2 business days.
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