Argentine Republic v. Amerada Hess Shipping Corp., 488 U. S. 428, 434 (1989). Under the FSIA, foreign states—including foreign agencies and other state instrumentalities—are presumptively immune from the jurisdiction of U.S. courts unless one of the FSIA's exceptions to immunity applies. 28 U.S.C. §§ 1603, 1604. One frequently invoked exception is for actions commenced to confirm or enforce arbitral awards, which provides that: A foreign state shall not be immune from the jurisdiction of courts of the United States or of the States in any case ... in which the action is brought, either to enforce an [arbitration] agreement made by the foreign state with or for the benefit of a private party ... or to confirm an award made pursuant to such an agreement to arbitrate, if ... the agreement or award is or may be governed by a treaty or other international agreement in force for the United States calling for the recognition and enforcement of arbitral awards.