Jurisdiction and enforcement of judgments of international commercial courts: international experience and implications for Vietnam

This study examines two key components of the international commercial court model: jurisdiction and the enforceability of judgments. Through a functional comparison of the Dubai International Financial Centre Courts, the Singapore International Commercial Court, and the Astana International Financial Centre Court, it assesses the design of Vietnam’s Specialised Court under Law No. 150/2025/QH15. The findings show that Vietnam has adopted a model integrated into the People’s Court system, with an internal judgment enforcement mechanism. Although this design offers advantages in terms of speed, it presents three challenges: the absence of coordination procedures for enforcement against assets located outside the International Financial Centre, limited cross-border enforcement channels because Vietnam is not a party to the relevant Hague Conventions, and a legal gap concerning digital asset disputes. The study proposes four groups of solutions to improve the practical enforceability of judgments.