UK · EU · US · InternationalEnforcing a US judgment or award in England and Wales
Short answer: a US judgment is not registered in England. It is enforced by bringing a fresh claim on the judgment debt at common law, and several categories of US award do not survive the trip. An arbitral award is considerably easier.
The common law route
There is no reciprocal enforcement treaty between the United States and the United Kingdom. A US money judgment is enforced by suing on it in England as a debt. The English court does not re-hear the merits, but the claimant must show that the US court had jurisdiction in the English sense, that the judgment is final and for a definite sum, and that no defence such as fraud or public policy applies.
Three things that cause trouble
Jurisdiction in the English sense. The defendant must have been present in the state when proceedings began, or have submitted to that court. Long arm jurisdiction that satisfies the US constitutional test does not automatically satisfy the English one.
Punitive and multiple damages. English law does not enforce awards of multiple damages, and the Protection of Trading Interests Act 1980 restricts their enforcement expressly. A compensatory element can often be severed, but the punitive part will not travel.
Default judgments. Enforceable in principle, but they invite challenge on service and on whether the defendant genuinely submitted. Expect that argument to be run.
Why an arbitral award is the better instrument
An award made in the United States is enforceable in England under the New York Convention, with a short list of grounds on which the court may refuse. That is a fundamentally easier path than a fresh common law claim, and it is the strongest argument for putting an arbitration clause into a transatlantic contract at the drafting stage rather than wishing you had. See how to choose the clause.
What we do
We assess whether your judgment or award qualifies, prepare the enforcement strategy and the evidence, and identify the English assets worth pursuing. Court filings are made by instructed counsel with the file fully prepared.
Common questions
Can I register a US judgment in England?
No. There is no treaty route. You bring a fresh claim on the judgment debt at common law, and the English court examines jurisdiction and defences without re-hearing the merits.
Will punitive damages be enforced?
No. English law does not enforce multiple damages awards, and legislation restricts them expressly. A compensatory element can often be separated out.
Is an arbitration award easier?
Considerably. Both countries are parties to the New York Convention, so enforcement runs on an established route with a limited list of grounds for refusal.
Fixed fee agreed in writing before any work begins, written reply within twenty four hours, handled entirely in writing. See the United States desk or send your enquiry.