International Law - Miga, a French company

International Law Question

Miga, a French company, sold hundreds of millions of dollars worth of goods, much of it on credit, to various agencies of the Russian government. The first deals were made with the Union of Soviet Socialist Republics (USSR), then, after the collapse of that government in 1991, with the Federative Socialist Soviet Republic of Russia (RSFSR), the successor government. The agreements called for binding arbitration of any disputes at the Chamber of Commerce of Stockholm, Sweden, under Swiss law, and subject to enforcement in court in New York. Following failure to make payments, the arbitrator awarded Miga $275 million, which Russia refused to pay. Miga brought suit in federal court in New York to enforce the arbitration award.

You be the judge. Who wins? Why? Make sure you address all the issues.