In addition, the losing party may argue that the decision cannot be enforced because, due to sanctions, it would be contrary to the “public policy” of the country where the decision is being enforced. However, national courts often do not allow reference to public policy when it comes to unilateral sanctions (unlike, for example, international UN sanctions). In 2018, international arbitration in Paris ruled in favor of the Iranian company NGSC in a dispute with the French Sofregaz over a construction contract in Iran that was terminated due to various sanctions against the country. In 2019, Sofregaz asked the Paris Court of Appeal to overturn the arbitration award, citing that the project could not be completed due to sanctions. However, in 2020, the court rejected this request, ruling that unilateral US sanctions cannot be a basis for considering France’s international public order to be violated. At the same time, the court considered that UN resolutions or EU regulations imposing sanctions on Iran would be part of French public policy, since they are aimed at promoting international security and peace.