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take steps to locate the country or countries in which the losing party has assets upon which to levy execution;
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consider ‘forum shopping’, in order to attain the quickest and most effective result, if these assets are located in different countries; and then
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take advice, from experienced lawyers in the relevant country or countries, as to whether it is preferable (if the option is open) to proceed under the New York Convention (or any other relevant treaty) or to seek enforcement under a more favourable local law.
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For unsuccessful party
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take the initiative by challenging the award in the courts at the place where it was made;
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do nothing until the winning party makes the first move;
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use the award as the starting point for a negotiating process.
The losing party is that he cannot go ‘forum shopping’. If he decides to challenge the award, he must usually do so in the competent court at the place of arbitration. If he decides to resist enforcement, he must do so in the national court of the enforcement forum.
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Source: Redfern and Hunter on International Arbitration
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