Introduction
Arbitration is one of the principal dispute resolution mechanisms used in international trade, construction, energy, finance, transportation, technology, corporate transactions and foreign investment. Businesses frequently select arbitration because it allows them to choose a neutral forum, appoint specialist decision-makers and obtain an award that may be enforceable in jurisdictions where the losing party owns assets.
Obtaining a favourable arbitral award, however, does not always result in voluntary payment. If the unsuccessful party fails to comply with the award, the award creditor must take legal steps to convert the arbitral decision into an enforceable instrument against assets located in Turkey.
The recognition and enforcement of arbitral awards under Turkish law depends primarily on where the arbitration was legally seated and which arbitration regime governed the proceedings. Awards rendered in arbitrations seated in Turkey are treated differently from foreign arbitral awards. Foreign awards may be subject to the 1958 New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards, the Turkish International Private and Procedural Law No. 5718, another applicable international treaty or a combination of these legal instruments.
Turkey’s legal framework is generally based on the principle that arbitral awards should be recognised and enforced unless one of the limited statutory or treaty-based grounds for refusal is established. Turkish courts conducting recognition or enforcement proceedings do not function as appellate tribunals and should not reconsider the merits of the dispute.
This guide explains the difference between recognition and enforcement, identifies the relevant Turkish legislation, examines the competent courts and required documents, and analyses the grounds on which an arbitral award may be refused recognition or enforcement in Turkey.
Understanding the Different Categories of Arbitral Awards
Before starting proceedings in Turkey, the award creditor must correctly classify the arbitral award. The applicable procedure differs depending on whether the award was rendered in a domestic arbitration, an international arbitration seated in Turkey or an arbitration seated outside Turkey.
Domestic Arbitral Awards Seated in Turkey
Domestic arbitration is principally governed by Articles 407 to 444 of the Turkish Code of Civil Procedure No. 6100.
These provisions generally apply where:
- The dispute does not contain the foreign element defined by the Turkish International Arbitration Law;
- The legal seat of arbitration is located in Turkey.
A domestic arbitral award is not a foreign award. Therefore, it does not require recognition or enforcement under the New York Convention or the foreign-award provisions of Law No. 5718.
The award is subject to the domestic setting-aside and execution framework established by the Code of Civil Procedure.
International Arbitral Awards Seated in Turkey
An arbitration may be international while still being legally seated in Turkey. Such proceedings are principally governed by the Turkish International Arbitration Law No. 4686 where the statutory foreign-element requirements are satisfied.
An award rendered in an international arbitration seated in Istanbul, Ankara or another Turkish city is not ordinarily treated as a foreign award merely because the parties are from different countries or the proceedings were conducted in English.
A Turkey-seated international award is subject to the setting-aside regime of Law No. 4686. Its execution in Turkey requires compliance with the enforceability procedure established under Article 15 of that law. Turkish case law has emphasised the importance of obtaining the required enforceability document before commencing compulsory execution based on an award governed by the International Arbitration Law.
Foreign Arbitral Awards
An award rendered in an arbitration legally seated outside Turkey will ordinarily be treated as a foreign arbitral award for Turkish recognition and enforcement purposes.
Examples may include awards seated in:
- London;
- Paris;
- Geneva;
- Zurich;
- Dubai;
- Singapore;
- Stockholm;
- Vienna;
- New York.
The name of the administering institution is not decisive by itself. An ICC, LCIA, SIAC or ad hoc award may be Turkish or foreign depending primarily on the legal seat and applicable procedural framework.
Correct classification is critical. Applying for “enforcement of a foreign award” where the award is legally Turkey-seated, or seeking only an enforceability certificate for an award seated abroad, may lead to procedural objections, loss of time and additional costs.
Legal Framework for Recognition and Enforcement in Turkey
The principal legal sources are:
- The New York Convention;
- Law No. 5718 on International Private and Procedural Law;
- The Turkish International Arbitration Law No. 4686;
- The Turkish Code of Civil Procedure No. 6100;
- Relevant bilateral and multilateral treaties;
- Turkish court-organisation and enforcement legislation.
Article 1 of Law No. 5718 expressly preserves the application of international conventions to which Turkey is a party. Therefore, where the New York Convention or another applicable treaty governs the award, treaty provisions take priority within their scope.
The applicable instrument should be identified before the petition is drafted. The legal team should determine:
- The country of the seat;
- Whether that country is a party to the New York Convention;
- Whether the dispute is commercial under Turkish law;
- Whether another treaty applies;
- Whether the award is final or binding;
- Whether setting-aside proceedings are pending at the seat;
- Whether the debtor owns assets in Turkey.
The New York Convention and Turkey
The New York Convention is the principal international legal instrument governing the recognition and enforcement of foreign and non-domestic arbitral awards. Its purpose is to prevent discrimination against foreign awards and to require contracting states to recognise and generally enforce qualifying arbitral awards under conditions comparable to those applicable to domestic awards.
Turkey has made two declarations under Article I(3) of the Convention.
First, Turkey applies the Convention on the basis of reciprocity to awards made in the territory of another contracting state.
Second, Turkey applies the Convention only to disputes arising from legal relationships, whether contractual or non-contractual, that are considered commercial under Turkish law.
Accordingly, before relying on the Convention, the applicant should confirm that:
- The award was rendered in the territory of a contracting state; and
- The underlying legal relationship qualifies as commercial under Turkish law.
The commercial-reservation requirement is normally satisfied in disputes arising from international sales, construction, supply, distribution, transportation, corporate transactions, banking, insurance, energy and similar business relationships.
Where the Convention does not apply because of Turkey’s reservations, this does not necessarily mean that enforcement is impossible. Law No. 5718, another international treaty or applicable reciprocity principles may provide an alternative legal basis.
Recognition and Enforcement: What Is the Difference?
Recognition and enforcement are related but legally distinct concepts.
Recognition of an Arbitral Award
Recognition means that the Turkish legal system accepts the award’s legal effect.
A recognised award may be relied upon:
- As a final determination of an issue;
- As a defence against a claim already decided;
- To establish res judicata;
- As conclusive evidence where legally applicable;
- In related judicial or administrative proceedings.
Recognition may be sufficient where the award does not require compulsory performance.
For example, an award dismissing a claim or declaring that one party has no liability may need to be recognised so that the same dispute cannot be litigated again in Turkey.
Law No. 5718 provides that recognition of foreign arbitral awards is governed by the same rules applicable to their enforcement.
Enforcement of an Arbitral Award
Enforcement gives the award executory effect in Turkey.
It is required where the award orders a party to:
- Pay money;
- Deliver property;
- Perform a contractual obligation;
- Refrain from particular conduct;
- Pay interest, costs or compensation.
After the Turkish court grants enforcement, the award may be executed through the Turkish enforcement system in the same manner as a Turkish court judgment, subject to the terms of the enforcement decision.
An award creditor seeking recovery from bank accounts, vehicles, shares, commercial receivables, movable assets or real estate in Turkey will generally require enforcement rather than recognition alone.
Which Awards May Be Enforced under Law No. 5718?
Article 60 of Law No. 5718 states that a foreign arbitral award may be enforced where it has become final and enforceable or is binding on the parties.
The expression “binding” is important. Under many arbitration systems, an award becomes binding when issued or notified, even though an extraordinary challenge or setting-aside application remains possible.
The applicant should submit evidence showing the award’s legal status. Depending on the seat and institutional rules, this may include:
- A statement in the award that it is final and binding;
- An institutional confirmation;
- A certificate issued at the seat;
- Evidence of notification to the parties;
- A legal opinion on the law of the seat;
- A court document concerning the status of any challenge.
If the award has been set aside or suspended by a competent authority at the seat, recognition and enforcement may be refused. A pending challenge does not always require automatic refusal, but it may affect the Turkish court’s procedural assessment.
Competent Court and Territorial Jurisdiction
The recognition or enforcement application must be filed before the competent Turkish court.
Article 60 of Law No. 5718 provides a hierarchy for territorial jurisdiction.
The parties may first agree in writing on the Turkish place where enforcement proceedings will be brought.
If there is no such agreement, jurisdiction belongs to the court of:
- The respondent’s domicile in Turkey;
- If no domicile exists, the respondent’s habitual residence in Turkey;
- If neither exists, the place where assets capable of enforcement are located.
In a commercial dispute, the application is generally brought before the Commercial Court of First Instance. Where the underlying matter is non-commercial, the Civil Court of First Instance may be competent. Court-organisation legislation specifically places foreign arbitral award recognition and enforcement proceedings among the arbitration matters handled by commercial court panels where commercial jurisdiction applies.
The applicant should verify both subject-matter jurisdiction and territorial jurisdiction before filing. A jurisdictional error may result in transfer proceedings and considerable delay.
Who May Request Recognition or Enforcement?
A party with a legal interest in recognition or enforcement may apply.
This will usually be:
- The successful claimant;
- A successful respondent with a costs award;
- An assignee of the award claim;
- A successor following a merger or corporate restructuring;
- An insolvency administrator or authorised representative;
- Another person legally entitled to rely on the award.
Where the award has been assigned, the applicant must also establish the validity of the assignment and its entitlement to enforce.
Corporate name changes, mergers, liquidations and changes in legal personality should be documented carefully. The Turkish court must be able to connect the applicant to the party named in the arbitral award.
Documents Required for Enforcement
Under Article 61 of Law No. 5718, the applicant must submit:
- The original arbitration agreement or arbitration clause, or a duly certified copy;
- The original arbitral award that has become final, enforceable or binding, or a duly certified copy;
- Duly certified Turkish translations of those documents;
- Copies corresponding to the number of opposing parties.
Article IV of the New York Convention similarly requires the authenticated original award or a duly certified copy and the original arbitration agreement or a duly certified copy. Where the documents are not in the official language of the enforcement jurisdiction, a certified translation may be required.
In practice, the file may also require:
- A Turkish power of attorney;
- Corporate registry documents;
- Proof of authorised representation;
- Evidence that the award was notified;
- Documentation concerning finality or binding effect;
- Apostille or consular legalisation where applicable;
- Documents showing the respondent’s Turkish address or assets;
- Evidence concerning the law applicable to the arbitration agreement.
Translations should be complete and consistent. The names of parties, monetary amounts, interest periods and operative provisions must be translated accurately.
A translation error affecting the dispositive section may create serious uncertainty during both enforcement proceedings and subsequent compulsory execution.
Procedure before the Turkish Court
Recognition and enforcement proceedings are adversarial.
The petition and hearing date are served on the respondent. The case is examined under the simplified procedure through the corresponding application of Articles 55, 56 and 57 of Law No. 5718. The court may grant full enforcement, grant enforcement only for part of the award or reject the application.
The respondent may present objections based on the limited grounds permitted under:
- Article V of the New York Convention;
- Article 62 of Law No. 5718;
- Another applicable treaty.
The respondent cannot turn the enforcement case into a second arbitration or an ordinary appeal.
The court’s role is limited to determining whether a recognised ground for refusal exists.
No Review of the Merits
One of the most important principles of international arbitration is the prohibition against reviewing the merits of the award, often described as the révision au fond prohibition.
A Turkish enforcement court should not reconsider:
- Whether the arbitrators interpreted the contract correctly;
- Whether a witness was credible;
- Whether an expert’s methodology was persuasive;
- Whether damages should have been higher or lower;
- Whether another legal interpretation was possible;
- Whether the tribunal made an ordinary error of fact or law.
The recognition and enforcement court is not an appellate tribunal.
Judicial review is confined to the grounds listed in the applicable convention or legislation. This limited review protects finality, which is one of the principal commercial advantages of arbitration.
A respondent’s disagreement with the tribunal’s factual findings or legal reasoning is not, by itself, a valid reason to refuse enforcement.
Grounds for Refusing Recognition or Enforcement
The grounds for refusal under Article V of the New York Convention and Article 62 of Law No. 5718 are broadly parallel.
They must be interpreted within the principle that enforcement is the rule and refusal is exceptional.
Absence or Invalidity of the Arbitration Agreement
Enforcement may be refused where:
- No arbitration agreement was concluded;
- The alleged signatory lacked authority;
- A party lacked legal capacity;
- The arbitration clause was invalid under the chosen law;
- In the absence of a chosen law, the clause was invalid under the relevant law of the seat;
- The applicant seeks enforcement against a person that never consented to arbitration.
The enforcement court may examine whether a valid written arbitration agreement exists.
However, the arbitration agreement is generally separable from the principal contract. The alleged invalidity or termination of the underlying commercial agreement does not automatically invalidate the arbitration clause.
Challenges involving non-signatories, guarantors, parent companies, assignees and successors require detailed examination of consent and applicable law.
Lack of Proper Notice or Denial of the Right to Be Heard
Enforcement may be refused if the respondent:
- Was not properly informed of the appointment of an arbitrator;
- Did not receive notice of the arbitration;
- Was not given a reasonable opportunity to present its defence;
- Was denied access to material submissions or evidence;
- Was prevented from participating in the hearing;
- Was otherwise deprived of basic procedural fairness.
Law No. 5718 expressly addresses failure to notify a party of the appointment of arbitrators and deprivation of the opportunity to submit claims and defences.
The right to be heard does not mean that every procedural request must be accepted. An arbitral tribunal may reject irrelevant evidence, enforce procedural deadlines and limit repetitive submissions.
Refusal normally requires a serious procedural deficiency that materially affected the party’s ability to present its case.
Irregular Representation
Article 62 of Law No. 5718 also addresses situations where a party was not properly represented before the tribunal and did not subsequently approve the procedural acts.
This issue may arise where:
- Counsel lacked authority;
- Corporate approval was missing;
- A legal representative acted beyond the scope of authority;
- A party was subject to guardianship or incapacity restrictions.
The assessment may require consideration of both the law governing representation and the law applicable to the party’s legal status.
Excess of Authority
An arbitral tribunal may decide only the matters submitted to arbitration.
Enforcement may be refused where the tribunal:
- Decided a claim outside the arbitration clause;
- Granted relief concerning a non-arbitrable or unsubmitted dispute;
- Determined rights of a person that was not a party;
- Exceeded an express contractual limitation on jurisdiction.
Article 62 permits refusal concerning the part of an award that addresses matters outside the arbitration agreement or exceeds its scope.
Where the authorised and unauthorised portions can be separated, partial enforcement may be possible. The entire award should not necessarily be refused because one severable part exceeds the tribunal’s mandate.
Improper Constitution of the Tribunal or Procedure
Enforcement may be refused if:
- The arbitrators were appointed contrary to the parties’ agreement;
- The tribunal did not have the agreed number of members;
- A mandatory appointment mechanism was ignored;
- The procedure violated the agreed institutional rules;
- In the absence of an agreement, the procedure violated the law of the seat.
Not every minor procedural deviation justifies refusal.
The alleged irregularity should be legally significant and should generally have affected the integrity of the proceedings.
A party that knowingly continued the arbitration without timely objecting may face arguments that it waived the objection.
Award Not Binding, Set Aside or Suspended
Recognition or enforcement may be refused where the award:
- Has not yet become binding;
- Has been set aside by the competent authority at the seat;
- Has been suspended;
- Has not acquired enforceable status under the applicable legal system.
Article 62 of Law No. 5718 expressly includes awards that have not become final, enforceable or binding, or have been annulled by the competent authority of the country where they were rendered.
Where setting-aside proceedings are merely pending, the Turkish court must evaluate the circumstances under the applicable convention. Under Article VI of the New York Convention, the enforcement court may adjourn its decision and may require appropriate security.
An award debtor should not be able to delay enforcement indefinitely merely by initiating tactical proceedings at the seat. Conversely, enforcement of an award that has already been lawfully annulled may raise substantial legal difficulties.
Non-Arbitrability
A Turkish court may refuse enforcement where the subject matter cannot legally be resolved by arbitration under Turkish law.
Turkish arbitration legislation generally excludes:
- Disputes concerning rights in rem over immovable property located in Turkey;
- Matters that are not subject to the parties’ free disposition.
Most ordinary commercial payment, construction, supply, corporate and international trade disputes are arbitrable.
More careful analysis is required for disputes involving:
- Ownership of Turkish real estate;
- Bankruptcy status;
- Certain corporate-status matters;
- Criminal liability;
- Administrative sanctions;
- Family status;
- Mandatory rights that parties cannot freely waive.
A commercial dispute connected with real estate is not automatically non-arbitrable. A payment claim under a construction contract may be arbitrable even though the project concerns a building. A direct determination of title to Turkish immovable property is a different matter.
Public Policy
Public policy is one of the most frequently invoked grounds for resisting enforcement.
Article 62 of Law No. 5718 provides for refusal where the award is contrary to public morality or public policy.
Public policy should not be used as a disguised appeal.
The fact that:
- The tribunal applied foreign law;
- Turkish law would have produced a different result;
- The court disagrees with the arbitrators;
- The damages are substantial;
- The tribunal made an arguable legal error;
does not automatically establish a public-policy violation.
The relevant question is generally whether recognising or enforcing the operative result of the award would produce a manifest conflict with fundamental principles of the Turkish legal system.
The Turkish Court of Cassation has distinguished international public policy from broader domestic public-policy concepts and has described the international standard as narrower.
Potential public-policy concerns may include:
- Serious violations of due process;
- Enforcement of an unlawful or prohibited obligation;
- Fraud directly affecting the integrity of the proceedings;
- Results fundamentally incompatible with constitutional principles;
- Enforcement that would legitimise corruption or criminal conduct.
Public-policy analysis is fact-specific. It should be based on the consequences of enforcement rather than a full reassessment of the merits.
Burden of Proof
The allocation of the burden of proof is important.
Under the New York Convention, the party resisting recognition or enforcement generally bears the burden of proving the grounds listed in Article V(1), such as invalidity, lack of notice, excess of authority, procedural irregularity or the award’s non-binding status.
The enforcing court may consider non-arbitrability and public policy under Article V(2).
Law No. 5718 similarly places the burden regarding several listed objections on the party against whom enforcement is requested. Article 62 expressly allocates the burden to that party for irregular representation, lack of notice or defence, invalidity, procedural irregularity, excess of authority and the award’s legal status.
The award creditor must nevertheless establish the preliminary requirements by submitting the award, arbitration agreement, translations and evidence of binding effect.
Partial Recognition and Enforcement
An award may contain several independent rulings.
For example, the tribunal may decide:
- Principal debt;
- Interest;
- Contractual penalties;
- Costs;
- Declaratory relief;
- Counterclaims.
If one portion falls outside the arbitration agreement or encounters another enforcement obstacle, the remaining separable portions may still be enforced.
Law No. 5718 permits the court to grant partial enforcement and specifically contemplates refusal only for the part exceeding the scope of the arbitration agreement where separation is possible.
The application should identify clearly which parts of the award are being relied upon. Where only part is sought, the petition should explain why that portion is legally and mathematically separable.
Enforcement after the Court Decision
Once the enforcement decision becomes capable of execution, the arbitral award may be enforced like a Turkish court judgment.
The award creditor may commence judgment-based enforcement proceedings against assets in Turkey.
Potential targets include:
- Bank accounts;
- Commercial receivables;
- Vehicles;
- Machinery;
- Shares in Turkish companies;
- Intellectual-property rights;
- Movable property;
- Real estate.
The enforceable amount must be calculated in accordance with the operative part of the award and the Turkish court’s enforcement decision.
Interest, currency conversion, costs and partial payments must be handled carefully. The enforcement office cannot modify or expand the arbitral award.
Law No. 5718 provides that decisions granting or refusing enforcement are subject to the ordinary appellate framework and that the appellate challenge has suspensive effect on execution.
Asset Preservation and Enforcement Strategy
A legally successful award may have little commercial value if no recoverable assets can be located.
Before or during recognition and enforcement proceedings, the creditor should investigate:
- The debtor’s registered address;
- Company registry information;
- Real estate;
- Vehicles;
- Shares;
- Business receivables;
- Known banking relationships;
- Transfers to related companies;
- Insolvency or restructuring proceedings.
Interim attachment or other protective measures may be considered where the statutory conditions are satisfied. The availability and scope of such relief depend on the claim, evidence, urgency and the nature of the debtor’s assets.
The enforcement strategy should be developed before filing the petition. Waiting until the recognition and enforcement judgment is final may give the debtor time to reorganise or transfer assets.
Common Mistakes in Enforcement Applications
Frequent procedural and strategic mistakes include:
- Misclassifying a Turkey-seated award as foreign;
- Relying on the New York Convention without checking Turkey’s reservations;
- Filing before the wrong court;
- Failing to identify assets in Turkey;
- Submitting an incomplete arbitration clause;
- Providing uncertified or inconsistent translations;
- Failing to prove that the award is binding;
- Omitting corporate succession documents;
- Requesting enforcement of relief that is not clearly stated in the award;
- Ignoring pending setting-aside proceedings;
- Treating enforcement as an appeal on the merits;
- Waiting too long before analysing limitation issues.
These errors can delay recovery even where the award is substantively strong.
Practical Checklist for Award Creditors
Before initiating proceedings, the award creditor should confirm:
- The legal seat of arbitration;
- Whether the award is Turkish or foreign;
- Whether the New York Convention applies;
- Whether the underlying relationship is commercial;
- Whether the award is binding or enforceable;
- Whether any challenge is pending at the seat;
- Which Turkish court has jurisdiction;
- Whether the debtor has assets in that jurisdiction;
- Whether all originals, certified copies and translations are available;
- Whether interim protection is necessary;
- Whether full or partial enforcement will be requested;
- Whether the award has been partially paid or satisfied.
The legal and asset-recovery strategies should be coordinated.
Frequently Asked Questions
Can a foreign arbitral award be enforced directly through a Turkish enforcement office?
Ordinarily, no. A foreign award must first be recognised and granted enforcement by the competent Turkish court. After the court grants enforcement and the decision becomes executable, compulsory execution may begin.
Is recognition sufficient for a monetary award?
Usually not. A monetary award requires enforcement because the creditor seeks compulsory collection rather than only acceptance of the award’s legal effect.
Can the Turkish court reconsider the amount of damages?
The court should not review the merits or recalculate damages. Its examination is limited to the statutory or treaty-based grounds for refusal.
Can an ICC award be enforced in Turkey?
Yes, provided the applicable recognition and enforcement requirements are satisfied. The identity of the institution does not eliminate the need to examine the seat, binding nature, arbitration agreement, due process and public policy.
Must the award be final?
The award must have become binding or acquired the status required by the applicable instrument. Under the New York Convention, “binding” is generally more important than the terminology used for domestic court judgments.
Can an award that has been set aside at the seat be enforced?
An annulment at the seat is a recognised ground for refusing enforcement. The precise result depends on the applicable convention, the circumstances of the annulment and the arguments presented to the Turkish court.
Can only part of an award be enforced?
Yes. Partial enforcement may be possible where the enforceable and unenforceable portions are separable.
Is public policy interpreted broadly?
It should be interpreted restrictively in the international enforcement context. Public policy is not intended to permit a new examination of the merits.
How long does enforcement take?
The duration depends on the competent court, service of process, objections, evidence concerning foreign law, appeals and the complexity of the award. A precise timeframe cannot be guaranteed.
Legal Services for Recognition and Enforcement of Arbitral Awards in Turkey
An arbitration lawyer in Turkey may assist with:
- Classifying the award;
- Determining the applicable treaty and legislation;
- Reviewing the arbitration agreement;
- Identifying the competent court;
- Preparing the recognition and enforcement petition;
- Coordinating certification and translation;
- Responding to public-policy and due-process objections;
- Investigating assets;
- Seeking protective measures;
- Conducting compulsory execution;
- Defending against improper enforcement applications;
- Advising on setting-aside and parallel proceedings.
Early legal analysis is particularly important where the debtor may dispose of assets or where a challenge is pending at the seat.
Conclusion
The recognition and enforcement of arbitral awards under Turkish law is governed by a structured legal framework that distinguishes Turkey-seated awards from foreign arbitral awards.
Foreign commercial awards rendered in another contracting state are generally assessed under the New York Convention, subject to Turkey’s reciprocity and commercial reservations. Where the Convention does not apply, Law No. 5718 or another international treaty may provide the relevant legal basis.
Law No. 5718 requires the applicant to submit the arbitration agreement, the binding or enforceable award and duly certified Turkish translations. The petition must be filed before the competent Turkish court determined according to the parties’ written agreement, the debtor’s Turkish domicile or residence, or the location of enforceable assets.
The Turkish court may refuse recognition or enforcement only on limited grounds, including invalidity of the arbitration agreement, lack of notice, denial of the right to be heard, excess of authority, irregular tribunal composition, non-binding or annulled status, non-arbitrability and public policy.
The court should not review the merits, reassess evidence or substitute its contractual interpretation for that of the arbitral tribunal.
Successful enforcement requires more than a favourable award. It requires correct classification, complete documentation, accurate translation, careful jurisdictional analysis and an effective asset-recovery strategy.
For businesses, investors and award creditors seeking recovery against assets located in Turkey, obtaining specialised Turkish arbitration and enforcement advice at an early stage can significantly reduce procedural risk and improve the prospects of actual collection.
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