On July 14, 2025, the United States District Court for the District of Columbia confirmed and entered judgment on an international arbitration award issued by the International Centre for the Settlement of Investments Dispute (“ICSID”) against the Republic of Armenia in favor of LBKM client, Mr. Edmond Khudyan.
The proceeding before Judge Reggie B. Walton lasted only fifteen months—from Mr. Khudyan’s petition to confirm filed on April 12, 2024 to the judgment entered on July 14, 2025. This period included the time taken to serve the Republic of Armenia in accordance with the Hague Convention on the Service Abroad of Judicial and Extrajudicial Documents in Civil or Commercial Matters dated November 15, 1965.
Fifteen months is fast for any contentious proceeding in U.S. federal court, but particularly quick for one involving a foreign sovereign and a cumbersome method of service.
In 2021, an ICSID arbitration tribunal had issued an award dismissing Mr. Khudyan’s international law claims against Armenia for lack of jurisdiction and ordering Mr. Khudyan to pay Armenia, but Mr. Khudyan successfully annulled that award in proceedings before an ICSID Annulment Committee in 2023 (see here). The annulment decision of July 21, 2023 revived Mr. Khudyan’s claims and awarded Mr. Khudyan his legal fees and costs in the annulment proceeding. Mr. Khudyan’s petition before the U.S. court was one to confirm the pecuniary obligation in the annulment decision.
Armenia tried to resist confirmation by claiming it was still owed money under the 2021 award. Judge Walton rejected this argument, agreeing with Mr. Khudyan that the annulment decision extinguished the payment due to Armenia “in its entirety.” Judge Walton relied on the “plain text” of the annulment decision and a letter that the Secretary-General of ICSID had written to Armenia (at Mr. Khudyan’s request) expressly noting the payment due to Mr. Khudyan under the annulment decision, without mentioning any purported amount due to Armenia.
Law360 provides a fuller analysis of Judge Walton’s opinion and judgment here (subscription may be required).
###
About LBKM
Lewis Baach Kaufmann Middlemiss PLLC is a boutique law firm focusing on international financial disputes, financial compliance, white collar defense and investigations, insurance and reinsurance, and cross-border commercial litigation and arbitration. The firm has offices in Washington, New York, and London.