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Charles W. Mooney, Jrhave adopted restricted immunity from execution for assets used forcommercial activity. 157 Most of these jurisdictions do not confinethe commercial exception to immunity to assets that have a connectionwith the claim asserted against the state. 158 Some others, like theDomestic Courts 182-84, 317-59 (2005).157 Banca Carige S.p.A Cassa Di Risparmio di Genova E Imperia v. Banco NacionalDe Cuba, [2001] Lloyd’s Rep. 147, [153] (Eng.) (“The English common law adoptedthe ‘restrictive’ theory of sovereign immunity [regarding issues of attachmentof a foreign State’s property].”); Société Sonotrach v. Migeon, 77 I.L.R. 525, 527 (Fr.Court of Cassation 1985) (“The assets of a foreign State are, in principle, not subjectto seizure, subject to exceptions in particular where they have been allocated for aneconomic or commercial activity . . . .”); Condor & Filvem v. Nat’l Shipping Co. ofNigeria, 33 I.L.M. 593 (It. Constitutional Court 1992), sub nom Condor & Filvem v.Minister of Justice, Case No. 329, 101 I.L.R. 394, 401-02 (It. Constitutional Court1992) (holding that restrictive immunity for execution applied as long the property“is not destined to accomplish public functions,” and allowing pre-judgment attachmenton a vessel of the State-owned Nigerian shipping company for unpaid priceof goods guaranteed by the Nigeria Central Bank and the State of Nigeria); Abbottv. Republic of S. Afr., 113 I.L.R. 412, 425-26 (Spain Constitutional Court (SecondChamber) 1992) (holding that there was no longer a general rule of internationallaw requiring foreign States to be granted absolute immunity from execution andallowing for execution of a State bank account for an unsatisfied judgment for salaryarrears due to a foreign State employee, provided the funds were clearly and exclusivelyallocated for commercial or economic activities).Restrictive immunity from execution is also generally observed outside of Europe.See Act on the Civil Jurisdiction of Japan with respect to a Foreign State, Act. No.24 of 2009, art. 18(1) (“A Foreign State, etc. shall not be immune from jurisdictionwith respect to proceedings of a civil execution procedures [sic] against the propertyheld by said Foreign State, etc. that is in use or intended for use by said ForeignState, etc. exclusively for other than government non-commercial purposes.”);Cresh Co. v. Nauru Fin. Corp., Tokyo Chiho Saibansho [Tokyo Dist. Ct.] Nov. 30,2000, 1740 HANREI JIHO [HANJI] 54, translated in 44 Japanese Ann. Int’l L.204 (2001) (holding that the restricted theory had been adopted). See also State ImmunityAct, R.S.C. 1985, c. S-18, §12(1)(b) (Can.) (“property of a foreign state thatis located in Canada is immune from attachment and execution . . . except where. .(b) the property is used or is intended for a commercial activity”); State ImmunityAct 1979, §15(4) (Cap 313 1979) (Sing.) (stating that the Act “does not prevent theissue of any process in respect of property [of a State] which is for the time being inuse or intended for use for commercial purposes.”); Foreign States Immunities ActAct 87 of 1981 §14(3) (S. Afr.) (stating that the Act “does not prevent the issue ofany process in respect of property [of a State] which is for the time being in use orintended for use for commercial purposes.”).158 Many sovereign immunity acts do not have a connection requirement. See StateImmunity Act, 1978, c. 33, § 13(4) (U.K.) (State immunity “does not prevent theissue of any process in respect of property which is for the time being in use orintended for use for commercial purposes.”); The State Immunity Ordinance, No.VI of 1981, § 14(2)(b) Pak. Code (1981) (Pak.) (“the property of a State, not be-225