Execution of Foreign Judicial Decisions: A Comparative Analysis of Legal Mechanisms in Kazakhstan, Russia, the USA, China, and European Countries

This article presents a comprehensive analysis of modern mechanisms for the recognition and enforcement of foreign judicial decisions, with a particular focus on practice in the Republic of Kazakhstan. The study covers the period 2018–2024 and is based on a comparative analysis of legislative norms, judicial practice, and international conventions in Kazakhstan, Russia, the USA, China, and European countries. Special attention is paid to the application of the principle of reciprocity, the influence of international trends and political factors on the enforcement of judicial decisions, and the identification of promising directions for the improvement of national legislation. The work relies on recent publications from reputable sources (Scopus, Web of Science, and analytical reports from leading consulting organizations) and demonstrates that the modernization of the legal mechanism for enforcing foreign judicial decisions is a crucial condition for enhancing trust in the national judicial system and strengthening international cooperation.