Expanding Opportunities for Overseas Enforcement of PRC Judgments and Awards

January 6, 2026

Amanda Rasmussen and Kristine Kwok examine the gradual expansion of reciprocal enforcement regimes and the growing recognition of PRC judgments and arbitral awards in major jurisdictions, highlighting increasingly favorable conditions for cross-border recovery. Recent PRC–Hong Kong legal developments, including the China–Hong Kong Reciprocal Enforcement Ordinance effective from January 2024, along with enforcement cases in the US, UK, Canada, Australia and Singapore reflect a more predictable landscape for recognition of PRC court judgments and arbitral awards overseas.

The article describes publicly available resources for asset tracing especially to identify directly held and unencumbered assets. It emphasizes that early asset tracing can help identify dissipation or fraudulent conveyance, establish a baseline for comparison over time, and support enforcement planning from the outset. It concludes that engaging advisors with experience in international arbitration, cross-border litigation, forensic accounting and investigations can enhance the likelihood of successful enforcement.

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