Since 2019 there has been a ‘Mutual Arrangement’ in place between Hong Kong and Mainland China to facilitate the enforcement in Mainland China of Hong Kong judgments – and vice versa. However, that Arrangement has had only limited effect due to stringent applicability requirements. They include a requirement that the relevant underlying commercial contract needed to specify which Chinese court would be handling the judgment enforcement process. The Arrangement also only applies to money judgments, so plaintiffs awarded injunctive and declaratory relief from the Hong Kong High Court were not assisted.