UK To Sign Judgments Convention

The United Kingdom has announced that it will the Judgments Convention in the near future. Note the word “sign,” not “ratify.” Several states, including the United States, have signed the Convention but not ratified it. The UK’s announcement does not set out a time for ratification, but it notes that ratification will not occur until implementing legislation is in place.

The UK’s move is not surprising, given Brexit and the EU’s ratification of the Convention. UK ratification will create a treaty-based system of judgment recognition between the UK and the EU to replace the system applicable within the EU. I hope the UK move will provide some additional impetus to US ratification. Indeed, the UK announcement states that the US is “due to ratify the Convention in the near future.” I hope the UK government knows something I don’t! (I have heard rumors about the possibility of a grand bargain on Judgments and COCA, but who knows?)

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