The enforcement of set aside awards continues to be one of the biggest misunderstandings of the New York Convention (NYC). Article V(1)(e) NYC makes it clear that an award shall cease to produce effects once it has been annulled by the courts of the seat. Disregarding such annulment decision by the courts of the primary jurisdiction frustrates the territorialist approach embedded in the Convention. Critically evaluate this statement, referring to relevant laws and materials as appropriate.