The Supreme Court denied the appeal filed against the decision of the Luxembourg Court of Appeal, which had granted exequatur of an SCC award. In respect of the New York Convention, the Supreme Court considered that the lower court had correctly applied the public policy reservation of Art. V(2)(b). In the context of exequatur proceedings, the review of the court is limited to the international concept of public policy. The party opposing enforcement argued that the Court of Appeal had incorrectly gone beyond that concept by applying the "manifest and determining fraud" (fraude manifeste et déterminante) standard. The Supreme Court found that, in fact, the lower court had concluded that no fraud at all had been proved.