International arbitration is a dynamically expanding concept in the five former U.S.S.R. republics of Central Asia. Positive changes reflect a rapidly growing volume of international commerce in that part of the world. However, international arbitration practice in Central Asia is not homogeneous. Only Kazakhstan, Uzbekistan, and Kyrgyzstan have so far acceded to the New York Convention, and among them only Kazakhstan has adopted legislation regulating international arbitration. In Turkmenistan and Tajikistan arbitration laws remain under consideration. This article analyzes the process of enforcement of foreign arbitral awards in those Central Asian republics that recognize the Convention. It familiarizes the reader with relevant legislation and focuses on interpretation and application of three important exceptions to enforcement under Article V of the Convention: procedural due process, arbitrability, and public policy.
Journal of International Arbitration