On 31 August 2018, the Supreme Court of Singapore and the Supreme People's Court of the People's Republic of China ("PRC") signed a Memorandum of Guidance ("MOG") on the recognition and enforcement of money judgments in commercial cases. The MOG sets out how a judgment issued by the courts of Singapore may be recognised and enforced in the courts of the PRC and vice-versa.
Although the MOG is not a treaty and has no binding effect, Chinese courts are expected to be "guided" by the MOG when it comes to enforcement of a Singapore judgments in China. The MOG sets out various conditions for the enforcement of Singapore judgments in China. Most importantly, the MOG stipulates that the courts of the PRC will not review the merits of a Singapore judgment and it may only be challenged on limited grounds of procedural and jurisdictional issues (unless the judgement violates public policy).