In an overwhelming majority of cases the recognition and enforcement of an arbitral award issued in a foreign jurisdiction is governed by the New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards with regard to the high number of state parties to this convention. In practice, the application of the New York convention often involves assessment of issues under its Article V. These issues relate to laws of jurisdictions where foreign arbitral awards are issued. Act no. 91/2012 Sb., on Private International Law, is similarly applied to foreign law issues arising under its Section 121.