What is the Gazprombank framework for foreign judgment enforcement?

Dutch term: Gazprombank-arrest | Legal basis: HR 26 September 2014

The Gazprombank framework, developed by the Dutch Supreme Court in its judgment of 26 September 2014 (ECLI:NL:HR:2014:2838), establishes the conditions under which a non-EU foreign judgment can be given effect in the Netherlands. Because the Netherlands has bilateral enforcement treaties with only a limited number of countries, most non-EU judgments require this route.

The four conditions are: (1) the foreign court had jurisdiction based on an internationally accepted ground, (2) the foreign proceeding respected due process, (3) the judgment is not contrary to Dutch public policy, and (4) the judgment is not irreconcilable with a Dutch or earlier recognised foreign judgment. When these conditions are met, the Dutch court gives the foreign judgment substantive effect without full relitigation.

Why it matters for international businesses

For creditors with a US, UK (post-Brexit), or other non-EU judgment seeking to enforce against Dutch assets, the Gazprombank route is the available path. It works but adds time and cost compared to direct EU enforcement under Brussels I Recast.