New Guide: Unrecognised Foreign Judgments in Cyprus Insolvency Law
Economou & Co LLC has published a new guide examining whether an unrecognised foreign judgment can, by itself, support bankruptcy or winding-up petitions in Cyprus, in light of the UK Supreme Court’s decision in Drelle v Servis-Terminal LLC [2026] UKSC 29.
The current position under Cyprus law is that a foreign monetary judgment should not be relied upon as the standalone basis for bankruptcy or winding-up proceedings unless it has first been recognised. The guide considers the UK Supreme Court’s decision in Drelle v Servis-Terminal LLC, which applied the common-law “obligation principle”, and explains why it does not displace the Cyprus authorities in Uralmetprom v Besuno Ltd and Onexim Group Management Ltd v Rostex Enterprises Ltd, which require prior recognition and registration of the foreign decision.
It also sets out the practical steps for creditors to consider before commencing insolvency proceedings based on a foreign judgment or arbitral award, including whether recognition remains the safer route and whether reliance on the underlying contractual debt may offer an alternative basis.
Read the full guide here: Unrecognised Foreign Judgments in Cyprus Insolvency Law
The content of this article is valid as of the publication date mentioned above. It is intended to provide a general guide and does not constitute legal or professional advice, nor should be perceived as such. We strongly recommend that you seek professional advice before acting on any information provided.
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