By a 2012 award on liability and a 2013 award on quantum, an ICC tribunal had, respectively, found that the respondent had fraudulently had the appellant’s shares in a holding company sold at a low price to third parties the respondent controlled, and had awarded damages. A first instance court had denied exequatur of both awards, finding that the 2013 award violated due process because it was based on a report to which only respondent’s counsel had been given access, and that the 2012 award contradicted a Turkish criminal court decision that had acquitted the respondent from the accusation of fraud for lack of evidence. The Court of Cassation had first reversed this decision in its entirety (Turkey 6) and had then reinstated it in respect of the 2013 award. The court of first instance had issued a resistance decision, resisting the reversal. The General Assembly of the Court of Cassation reversed the resistance decision. While a foreign award contradicting a final Turkish court decision would violate public policy, the decision of the criminal court in this case had merely found that the evidence was not sufficient to prove fraud. Hence, there was no contradiction.