The main dispute between the parties in this confirmation proceeding was whether Citigroup had already complied with the Award based on its payment in part to Ozkaptan and in part to United Kingdom tax authorities. The Court granted confirmation of the AAA award, noting that confirmation of an award and compliance with its terms are distinct questions.
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301
The court discusses the principle that the procedure for the enforcement of awards under the Convention is governed by the lex fori, as well as procedural issues (such as the competent enforcement court) not falling under the specific cases of ¶¶ 302-307.