On 16 September 2026, the Supreme Court of Singapore and the Supreme Court of Korea signed two new instruments aimed at supporting the effective resolution of cross-border civil and commercial disputes:
- the Memorandum of Guidance as to the Enforcement of Money Judgments (“MOG“), which will provide greater clarity on the recognition and enforcement of money judgments between Singapore and Korea; and
- the Memorandum of Understanding on Cooperation Regarding Information on Foreign Law (“MOU“), which will establish a mechanism for the courts to obtain reliable information on each other’s laws and judicial practices.
Greater Clarity on Recognition and Enforcement of Money Judgments
The MOG sets out the Singapore and Korean courts’ understanding of the procedures and requirements for recognising and enforcing the money judgments of one jurisdiction in the other. It covers judgments requiring the payment of a sum of money and does not cover non-monetary reliefs or criminal orders, fines or penalties.
The MOG serves as a practical reference for litigants and practitioners in cross-border cases, by setting out the applicable legal requirements and procedures in both jurisdictions. This provides greater clarity and understanding for parties seeking to have a Singapore money judgment recognised and enforced in Korea, and vice versa. The MOG does not create any new rights of reciprocal enforcement, nor does it alter the domestic laws of either jurisdiction.
Reliable Information on Foreign Laws and Judicial Practices
The MOU establishes a mechanism for the Singapore and Korean courts to exchange information on their respective domestic laws and judicial practices, and applies where a court is required to consider the law of the other jurisdiction in an ongoing international civil or commercial case.
The Singapore and Korean courts deciding such cross-border cases will have a clearer and more efficient channel for obtaining reliable information on each other’s laws and judicial practices, including relevant legislation, judicial precedents, decisions, interpretations and court orders. This will support the courts in determining questions of foreign law more accurately and efficiently.
Click on the following link for more information:
- Supreme Court Media Release titled “Supreme Courts of Singapore and Korea Sign New Arrangements to Support Cross-Border Civil and Commercial Disputes” (available on the SG Courts website at www.judiciary.gov.sg)
If you have any queries on the above, please reach out to our team set out on this page.
For regional Dispute Resolution matters, please see Rajah & Tann Asia’s Dispute Resolution Practice for more information.
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