On June 11, 2021 Gov. Andrew Cuomo signed Chapter 127 of the Laws of 2021, the Uniform Foreign Country Money Judgments Act, amending CPLR Article 53, Recognition of Foreign Country Money Judgments. Although described in the Introducer’s Memorandum as an “update [of] New York’s foreign country money judgments recognition act consistent with the national uniform act proposed by the Uniform Law Commission in 2005,” the new law is anything but uniform.

‘Akhmedova v. Akhmedov’

An interesting case study for the application of the new law may be found in Akhmedova v. Akhmedov, filed in New York County Supreme Court (index number 155688/2018). There, plaintiff Tatiana Akhmedova sought recognition under CPLR Article 53 of substantial money judgments issued in her favor in a divorce action by the England and Wales High Court of Justice, Family Division, in 2016 (AAZ v. BBZ & Ors [2016] EWHC (Fam) 3234 (Dec. 15, 2016, Haddon-Cave, J.)) and in 2018 (Akhmedova v. Akhmedov [2018] EWHC (Fam) 23 (April 19, 2018, Haddon-Cave, J.)). These judgments against Tatiana’s ex-husband Farkhad Akhmedov and related entities amounted to more than US $600 million. Akhmedov was listed as a Russian oligarch in the Jan. 19, 2018 U.S. Treasury Department Report to Congress Pursuant to §241 of the Countering America’s Adversaries Through Sanctions Act of 2017 Regarding Senior Foreign Political Figures and Oligarchs in the Russian Federation and Russian Parastatal Entities.