The Court of Appeals confirmed a Dutch award, rejecting Venezuela’s argument that exequatur would violate public policy. While the arbitration was ongoing, Venezuela held a presidential election in which incumbent president Maduro claimed victory. However, Venezuela’s National Assembly declared the election results invalid and selected an Interim President, whom US President Trump recognized. Subsequent to these events, the arbitral tribunal allowed the Maduro government to appoint a new law firm to represent it. Venezuela resisted the application to confirm the ensuing award in the United States, claiming that, in permitting the Maduro regime to change counsel in the arbitration, the tribunal treated Maduro as if he were the legitimate President of Venezuela, thus contradicting President Trump’s exercise of his exclusive power to recognize a foreign government. The district court denied this argument, ruling that the Executive’s recognition power was not a cognizable public policy for the purpose of the public policy objection under the 1958 New York Convention. The Court of Appeals agreed, but found that it did not need decide whether the President’s recognition authority was a cognizable public policy under the Convention or whether an award’s exequatur could violate that authority, because it had already rejected in an earlier decision the proposition that exequatur would infringe on the President’s exclusive recognition power.