judgment seeks to enforce the revenue and taxation laws of a foreign jurisdiction; The judgement was obtained through an illegal transaction; The judgement is not conclusive. Recognition and enforcement in England and Wales In England and Wales, three avenues of enforcement methods and recognition rules exist: Statutory registration of foreign judgments regarding European Union Member States through Brussels Recast Regulation. Statutory application of foreign states which are party to bilateral treaties. Common law rules for foreign states which do not fall into the above categories. Judgments operating in personam, such as those not relating to in rem property rights, are only recognised as effective against particular parties, the material question becomes whether the judgment debtor is bound to abide to the judgment. It is recognised as binding on and against the party against whom it was given only if it was delivered by a court which, according to English law, was competent to deliver a judgment. Jurisdictional rules with regard to the foreign court are irrelevant. It is thus crucial for the court to determine whether the adjudicating court's own standards for recognition are satisfied by the facts; the adjudicating court must be satisfied not that the foreign court bears jurisdiction under its own rules, but whether, in the eyes of the English court, the foreign court has an 'international jurisdiction' competence. Once the court has been satisfied that it is right to recognise a foreign judgment as settled, known as res judicata, the party may then seek to enforce the foreign judgment. In order for a judgment to be considered res judicata, it must be final and conclusive in the court which pronounced it. Enforcement, as will be seen, is about collecting a debt. To be enforceable, a judgment must be recognised and must be a judgment for a fixed sum of money. In England and Wales, only money judgments with settled amounts are capable of being enforceable. English courts do not enforce foreign judgments, and a judgment creditor must bring a cause of action under English law and use the recognised foreign judgment to serve as conclusive evidence of an outstanding debt. The judgment must be on the merits, as held in The Sennar No 2 [1985] 1 WLR 490. There are two purposes for effecting recognition of a foreign judgment. Firstly, if a party defeats a foreign case, he may seek recognition of that decision to estop