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Foreign court judgments: recognition and enforcement, U.S. and Turkiye

A court judgment from one country is not automatically enforceable in another. A local court first recognizes it, under that country's own rules.

15 yearsOuter limit to start a recognition action in Texas, New Jersey and Virginia [1]
ReciprocityNeeded for enforcement in Turkiye (Art. 54), not for recognition (Art. 58) [5]
Final onlyThe judgment must be final where it was made (Texas 36A.003; Law No. 5718, Art. 50) [1]

Is this the right route?

A foreign judgment is not enforced automatically. In Texas, a court shall recognize a final foreign money judgment unless a listed ground applies, and the action must start within 15 years at most. In Turkiye, a court must first issue a tenfiz decision (Law No. 5718, Art. 50), and enforcement requires reciprocity (Art. 54). Divorce, support, tax and penalty judgments follow other rules.

Who it's for People and companies that hold a final court judgment from the U.S., Turkiye or another country, or face one, and need it recognized or resisted where the debtor or the assets are.

Key requirements

U.S. state acts cover final money judgments; taxes, fines and divorce or support judgments are outside
A U.S. court recognizes a covered judgment unless a listed ground applies
Turkiye needs a court enforcement decision (tenfiz) first (Law No. 5718, Art. 50)
Turkiye requires reciprocity for enforcement, not for recognition (Arts. 54 and 58)

How it works

Get the judgment, proof that it is final, and a certified translation. Finality is judged under the law of the court that issued it (Tex. 36A.003(a); Law No. 5718, Art. 50(1)).
Decide where the debtor lives or holds assets. That decides which court and which country's rules apply.
In the U.S., file an action seeking recognition, or raise recognition as a counterclaim, cross-claim or defense in a pending case (Tex. 36A.006; N.J.S.A. 2A:49A-16.6).
In Turkiye, file a tenfiz petition with the court at the debtor's residence, with the documents listed in Arts. 52 and 53.
Prepare for the other side's objections: the U.S. grounds in Tex. 36A.004 and the Turkish conditions in Arts. 54 and 55(2).
After recognition, enforce: in the U.S. like a local judgment (Tex. 36A.007), in Turkiye like a Turkish judgment (Art. 57(1)).

Typical times

Texas: action to recognize a foreign-country judgmentWithin the earlier of the time the judgment is effective abroad or 15 years after it became effective there [1]
New Jersey: action to recognize a foreign-country judgmentNot before the judgment is effective abroad, and not after 15 years from the date it became effective there [2]
Virginia: action to recognize a foreign-country judgmentWithin the earlier of the time the judgment is effective abroad or 15 years after it became effective there [4]
Turkiye: effect of a foreign judgment that is recognizedFrom the moment the foreign judgment became final [5]
Turkiye: enforcement while an appeal against a tenfiz decision is pendingSuspended until the appeal is decided [5]
Court time to decide recognition or tenfizVaries by court and by how the other side responds

Note 1

Foreign judgments: questions people ask

can a us judgment be enforced in turkey

Only after a Turkish court issues a tenfiz decision (Law No. 5718, Art. 50(1)). The court checks conditions, including reciprocity with the issuing state, public order and proper summons (Art. 54(1)). It examines reciprocity in each case. An attorney prepares the petition and the certified papers.

can a turkish court judgment be enforced in the us

A U.S. state court recognizes a final foreign money judgment unless a ground applies (for example Tex. Civ. Prac. & Rem. Code 36A.004 or N.J.S.A. 2A:49A-16.4). Each state has its own act and grounds. Texas lists lack of reciprocity as one ground (36A.004(c)(9)); the New Jersey text we read has none.

how long do i have to enforce a foreign judgment in the us

In Texas and Virginia, the earlier of the time the judgment is effective abroad or 15 years after it became effective there (Tex. 36A.009; Va. Code 8.01-465.13:8). New Jersey allows no action after 15 years (N.J.S.A. 2A:49A-16.9). Check the issuing country's own period as well.

does tenfiz need reciprocity

Enforcement does. Law No. 5718 Art. 54(1)(a) asks for a treaty, a legal provision or actual practice in the issuing state that lets Turkish judgments be enforced. Recognition (tanima) does not need it (Art. 58(1)). The court examines the point in each case.

what documents do i need to enforce a foreign judgment in turkey

A certified original or copy of the judgment with a certified translation, and a certified document showing that it is final (Law No. 5718, Art. 53). The petition names the parties, the issuing court and the judgment's date and number (Art. 52).

Discuss your matter with our team

We check the judgment and where the assets are, prepare the recognition or tenfiz filing with the certified papers and translations, and review the grounds the other side can raise. Work on Turkish law is done with collaborating independent counsel in Turkiye.

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Documents to prepare

The judgment, certified by the issuing court or the authorities of the issuing country, with proof that it is final.
A certified translation of the judgment and of the finality document, required in Turkiye.
Proof of service on the defendant and of any appearance in the case.
Proof of where the debtor lives or holds assets: land registry (tapu) extracts, bank details, company registry records.
The contract the case was about and any agreement choosing the court.
Evidence of any payment already made.
Powers of attorney, if a representative files for you.

Common reasons for refusal or delay

Assuming a judgment is final: the acts cover only judgments that are final, conclusive and enforceable where they were made (Tex. 36A.003(a)).
Waiting too long: a U.S. recognition action has an outer limit of 15 years in Texas, New Jersey and Virginia.
A default judgment: in New Jersey the party seeking recognition must then show jurisdiction and service (N.J.S.A. 2A:49A-16.4(d)).
Missing papers in Turkiye: the petition needs the certified judgment, a translation and proof that it is final (Art. 53).
Treating reciprocity as certain: in Turkiye it is a condition for enforcement, and the court examines it in each case (Art. 54(1)(a)).
Using a money-judgment act for a divorce or tax judgment: the U.S. acts do not cover them.

When this is not the right route

Divorce, custody and support judgments: see Cross-border family law.
Foreign arbitral awards: they follow separate rules (Law No. 5718, Arts. 60 to 63); see Turkish-law matters.
A case still pending or on appeal in a Turkish court: that is Turkish procedure; see Turkish-law matters.
Funds blocked under U.S. sanctions: see OFAC and sanctions.

Full details

Who this is for

Creditors holding a final U.S. judgment against a debtor or assets in Turkiye.
Creditors holding a Turkish judgment against a debtor or assets in a U.S. state.
Defendants who want to resist recognition of a foreign judgment.
Companies and families with court decisions from other countries.

Key requirements

Scope in the U.S.: the acts cover a foreign-country judgment that grants or denies a sum of money and is final, conclusive and enforceable where it was made. They do not cover judgments for taxes, fines or penalties, or divorce, support and other domestic-relations judgments (Tex. Civ. Prac. & Rem. Code 36A.003; N.J.S.A. 2A:49A-16.3; CPLR 5302; Va. Code 8.01-465.13:2).
Recognition in the U.S.: a court shall recognize a covered judgment unless a ground applies (Tex. Civ. Prac. & Rem. Code 36A.004(a)). It may not recognize one from a system without impartial tribunals or due process, or where the foreign court lacked personal or subject-matter jurisdiction (36A.004(b)). The party resisting recognition carries the burden (36A.004(d)). In New Jersey, for a default judgment the party seeking recognition must show jurisdiction and service (N.J.S.A. 2A:49A-16.4(d)).
Other U.S. grounds: a court may refuse recognition, for example, for lack of timely notice, fraud, public policy, a conflicting judgment or a forum-selection agreement (Tex. 36A.004(c); N.J.S.A. 2A:49A-16.4(c); CPLR 5304(b); Va. Code 8.01-465.13:3(C)).
Reciprocity in the U.S.: Texas lists as a ground that the foreign country does not recognize Texas judgments (36A.004(c)(9)). The New York, New Jersey and Virginia provisions we read have no reciprocity ground.
Effect and time limit in the U.S.: a recognized judgment is enforceable like a local judgment (Tex. 36A.007). An action must be brought within the earlier of the time the judgment is effective abroad or 15 years (Tex. 36A.009; Va. Code 8.01-465.13:8). New Jersey bars an action after 15 years from the date the judgment became effective abroad (N.J.S.A. 2A:49A-16.9).
Enforcement in Turkiye: a final foreign civil judgment can be enforced in Turkiye only after a Turkish court issues a tenfiz decision (Law No. 5718, Art. 50(1)). The court of first instance (asliye mahkemesi) hears it, at the debtor's residence, or in Ankara, Istanbul or Izmir if the debtor has none in Turkiye (Art. 51).
Papers for Turkiye: a certified original or certified copy of the judgment with a certified translation, and a certified document showing that it is final (Art. 53). The petition names the parties, the issuing court, and the date, number and summary of the judgment (Art. 52).
Conditions in Turkiye: reciprocity (a treaty, a legal provision or actual practice in the issuing state that allows Turkish judgments to be enforced), a matter outside the exclusive jurisdiction of Turkish courts, no clear conflict with Turkish public order, and proper summons or representation of the defendant (Art. 54(1)). A defendant can also object that the issuing court had no real connection to the dispute or the parties. Whether reciprocity exists with a given country or state is examined by the Turkish court in each case; we do not assume the result.
Recognition in Turkiye (tanima): a foreign judgment is accepted as conclusive evidence or as a final judgment only after the court finds that it meets the enforcement conditions, but the reciprocity condition does not apply (Art. 58(1)).
Objections and enforcement in Turkiye: the defendant may object only that the conditions are missing or that the judgment has been performed (Art. 55(2)). A tenfiz decision is enforced like a Turkish judgment, and an appeal suspends enforcement (Art. 57).

What to check with an attorney

Is the judgment final where it was made, and can you prove it?
Is it a money judgment? Taxes, fines and family-law judgments follow other rules.
Where are the debtor and the assets? That decides the country and the court.
Which U.S. state's act applies, and does it have a reciprocity ground?
For Turkiye: do you have a certified copy, a certified translation and proof that the judgment is final?
Was the defendant properly served, and did the issuing court have jurisdiction?
The deadline: up to 15 years in the U.S. acts we read, plus the issuing country's own period.

Sources and review date

Sources reviewed 13 Nov 2026. Sources below.

Official sources:

What changed: new page on recognition and enforcement of foreign judgments in the U.S. and Turkiye.