The Civil Procedure Code allows the recognition of foreign judgments only if there is an international treaty between the Russian Federation and the state, the court of which made the corresponding decision. The article calls into question such an approach of the legislator, since in some cases distrust of a court of another state may lead to a violation of the rights of the defendant. The authors not only analyze the problem and the possible consequences of the current regulation, but also propose a solution, taking into account the approaches developed by doctrine and courts' practice.