The Court of Appeals affirmed the decision of the district court. The district court had confirmed an AAA award, dismissing the objection of public policy based on the argument that enforcement would violate US public policy because the award required Petrobras to pay damages based on a contract illegally procured through bribery. The Court of Appeals first noted that the public policy defense under the Panama Convention was substantively identical to the one set forth in the New York Convention; it then concluded that the district court had not erred in deferring to the arbitrators’ finding that Petrobras had ratified the allegedly illegal agreement, because under the New York Convention, the rulings of the arbitral tribunal interpreting the parties’ contract were entitled to deference.