The Court of Appeals affirmed the 2020 decision of the District Court (US no. 1003), which had confirmed an award rendered in France under the UNCITRAL Rules in a dispute arising under the Russia-Ukraine BIT. The Court held that the first instance court had neither exceeded its discretion nor made legal error when it denied Ukraine's motion for supplemental briefing on the issue of whether Art. (V)(1)(c) prevented enforcement, filed years after the parties had initially briefed the merits. Nor did the lower court exceed its authority under the New York Convention by modifying the award, because, the Court of Appeals found, the analysis section and the dispositif of the award were not internally inconsistent as to the provision of damages. The Court of Appeals further affirmed the finding of the district court that neither the public policy reservation nor the improper composition objection justified refusing enforcement under the Convention. First, the United States do not have a policy against enforcing arbitral awards predicated on (alleged) underlying violations of foreign law. Second, the failure of one of the arbitrators to disclose that Tatneft's law firm appointed him to another panel did not give rise to justifiable doubts as to his impartiality or independence. In applying the justifiable doubts standard, the Court referred to the 2004 IBA Guidelines as authority on the ethics of international arbitrators, and found that even under a strict interpretation of the IBA Guidelines, the arbitrator did not have a duty to disclose.