Enforcement of Foreign Judgments in Lebanon

Lebanon has long adopted a generally receptive approach to the recognition and enforcement of foreign judgments, subject to compliance with the conditions set out under the Lebanese Code of Civil Procedure (the “LCCP”). In practice, foreign judgments may be recognised and enforced in Lebanon through an exequatur procedure before the competent Lebanese courts. 

The applicable framework is primarily governed by Articles 1009 to 1024 of the LCCP, which regulate the recognition and enforcement of foreign judgments and foreign arbitral awards in Lebanon. 

The Exequatur Requirement

As a general rule, a foreign judgment cannot be directly enforced in Lebanon without first obtaining an exequatur order from the competent Lebanese court. Once the exequatur is granted, the foreign judgment becomes enforceable in Lebanon and may be executed through the competent Enforcement Bureau against the debtor’s assets located in Lebanon. 

Under Article 1013 of the LCCP, the application for exequatur is generally submitted before the President of the Civil Court of Appeal in the jurisdiction where:

  • the defendant resides or is domiciled; or

  • the assets subject to enforcement are located. 

Conditions for Enforcement

Lebanese courts do not automatically enforce foreign judgments. The applicant must demonstrate that the statutory conditions for recognition and enforcement are satisfied.

Under Article 1014 of the LCCP, the principal conditions include:

  • the foreign court must have had proper jurisdiction;

  • the judgment must be final and enforceable in the jurisdiction where it was rendered;

  • the defendant must have been properly notified and afforded due process rights;

  • the judgment must not violate Lebanese public policy; and

  • reciprocity must exist between Lebanon and the state in which the judgment was issued. 

The reciprocity requirement remains an important aspect of Lebanese enforcement proceedings. Lebanese courts generally require that the foreign jurisdiction in question recognises and enforces Lebanese judgments under comparable conditions. 

Review by Lebanese Courts

Lebanese courts do not ordinarily re-examine the merits of the foreign judgment itself. However, Lebanese courts retain limited authority to review certain issues in connection with the exequatur application, including questions relating to jurisdiction, due process and public policy. 

Article 1016 of the LCCP also provides that Lebanese courts must refuse enforcement in certain circumstances, including where:

  • a final Lebanese judgment already exists concerning the same dispute and parties; or

  • proceedings concerning the same dispute were initiated before Lebanese courts prior to the foreign proceedings. 

Foreign Arbitral Awards

Lebanon is a party to the 1958 New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards, having acceded to the Convention in 1998. 

As a result, foreign arbitral awards may generally be recognised and enforced in Lebanon subject to the requirements of the New York Convention and the relevant provisions of the LCCP. Lebanon has, however, adopted the reciprocity reservation under the Convention. 

Practical Considerations

While the Lebanese legal framework generally permits the enforcement of foreign judgments, the practical effectiveness and timing of enforcement proceedings will depend on several factors, including:

  • the nature of the judgment;

  • the jurisdiction in which it was rendered;

  • the existence of reciprocity;

  • procedural compliance;

  • the location of assets in Lebanon; and

  • potential public policy considerations.

Parties seeking to enforce foreign judgments or arbitral awards in Lebanon should therefore assess enforcement strategy at an early stage, particularly in cross-border transactions and disputes involving Lebanese counterparties or assets.

This publication is provided for general informational purposes only and does not constitute legal or tax advice.