An Uncertain Future For British Judgments In Germany

By Stephen Llewellyn and Karl von Hase (June 27, 2018, 1:08 PM EDT) -- As long as the U.K. remains part of the EU, enforceable judgments in civil and commercial matters rendered by its courts will be recognized in Germany under the EU Brussels Ia Regulation[1] without the requirement for any special procedure. Of course, the same applies to judgments from the other EU states. Up until Brexit, therefore, a British judgment can be enforced in Germany with the same authority as a German judgment. The British judgment creditor simply needs to present the judgment to be enforced to the German enforcement authority along with a "certificate of enforceability" issued by the British court that rendered the judgment....

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