D.C. Court Enforces Four ICSID Awards Against Spain, Clears Assignees
Two September 2026 D.D.C. opinions rejected Spain's EU-law defenses and held a non-party assignee may enforce ICSID awards, widening a transatlantic split with the English High Court's OperaFund ruling now on appeal.
In two late-September 2026 opinions, the U.S. District Court for the District of Columbia enforced four ICSID awards now held by assignee Blasket Renewable Investments against Spain (Eurus Energy Holdings v. Spain, No. 25-cv-1842; Blasket v. Spain, No. 25-cv-1756). The court held that ICSID awards carry full faith and credit under 22 U.S.C. § 1650a, and that the Blinder collateral-attack exception does not reach Spain's contention that intra-EU awards violate EU law or amount to unlawful state aid. Comity, foreign sovereign compulsion and act of state all failed: enforcing an award neither applies U.S. regulatory law to extraterritorial conduct nor invalidates EU Commission decisions.
Most consequential for the secondary award market, the court held an assignee that was not a party to the arbitrations may sue in its own name, following Blue Ridge Investments and diverging from the English High Court's OperaFund decision, which is on appeal. Read alongside the D.C. Circuit's NextEra FSIA ruling and the same court's September 30, 2026 Deutsche Telekom v. India remand ruling, D.D.C. is emerging as a predictable enforcement forum.
Watch asset attachment and actual collection, the English Court of Appeal, and EU institutional escalation. Holders of sovereign awards should file in D.C., structure assignments to survive scrutiny in every forum and identify attachable assets early.