Annotation: This Article provides an analysis of Russian legislation, as well as its interpretation in the decisions of the RF Constitutional Court and the RF Higher Arbitration Court, of the res judicata effect of awards of international commercial arbitration tribunals. The UN Convention on the Recognition and Enforcement of Foreign Arbitral Awards of June 10, 1958 and the judgments of the European Court of Human Rights have been proffered as grounds for adducing the res judicata effect to arbitral awards. This Article provides a research of the Principles of International Civil Procedure and the Resolution of the Association of International Law № 1/2006 “International Commercial Arbitration” regarding the res judicata effect of arbitral awards. It is argued that the matter of res judicata effect of arbitral awards requires international regulation.