ABSTRACT
As international arbitration is by far the preferred means of dispute resolution in international business, it is no surprise that most of such efforts have been made to facilitate the recognition and enforcement of arbitral awards rendered in international disputes. The most impactful international instrument created in that respect is the 1958 New York Convention for the Enforcement of Arbitral Awards Rendered Abroad. Domestic international public policy is also commonly distinguished from 'truly' transnational public policy, which might be described as the limited set of public policy principles common to all states. The Maximov case is only one of the recent examples of the French courts' attitude towards awards annulled at the place of arbitration. The trend of decisions is seen as having started with the Hilmarton case where an award was enforced in France despite having been set aside at the place of arbitration in Switzerland.
