A U.S. judgment.
Assets in Germany.

Check whether recognition is available

The applicable route must be assessed for the particular judgment. Under the German Code of Civil Procedure, relevant issues include the originating court's jurisdiction, proper service, conflicting decisions, German public policy and reciprocity.

Finality and the nature of the relief also matter. Default judgments and awards containing punitive elements require careful review. No general promise of recognition can be made from the judgment's U.S. origin alone.

Prepare the German proceedings

Under the general German statutory route, enforcement of a foreign judgment requires a German enforcement judgment. We review the decision and procedural record, identify required evidence and translations, and explain the likely German proceedings.

The scope may include working with your existing legal team to obtain the relevant documents. Responsibility for each workstream and its fees is agreed before work begins.

• Complete judgment and reasons, where available
• Evidence of service and the procedural history
• Information on finality and any appeal
• Debtor details and known German assets

Distinguish judgments from arbitral awards

A foreign arbitral award follows a different framework. Section 1061 of the German Code of Civil Procedure refers to the New York Convention on recognition and enforcement of foreign arbitral awards.

Tell us whether your document is a court judgment, arbitral award, settlement or payment order. That distinction affects both the legal assessment and the procedure.