...by the Federal Arbitration Act and the Uniform Arbitration Act of the United States. The legal regime of France stipulates an implied duty of confidentiality only in domestic arbitration and...
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...is nonetheless enforceable in France, so long as it satisfies French standards for enforcing arbtral awards. The “Chromalloy approach,” so-called after the leading American case on the subject, is that...
Enforcing Vacated International Arbitration Awards: An Economic Approach – Vol. ...
...Arbitration (France) from Kyrgyzstan. Natalia Alenkina is a member of the Scientific Advisory Council of the Supreme Court of the Kyrgyz Republic as well. † Hannepes holds an LL.B degree...
The ISDS Clause in the Investment Law of the Kyrgyz ...
...a few years ago, the Court dealt with disputes “across the Rhine” between French and German litigants. Now it has branches in Germany, Italy, France, Turkey, Croatia, Spain, Belgium and...
The European Court of Arbitration and its 1997 Rules* – ...
...Italy, France, Spain, Germany, etc.) to problems related to the applicability of an arbitration clause, particularly in the context of multi-contract transactions. I. ARBITRATION CLAUSES AND THEIR RELATIVE EFFECTS: A...
Relativity of Contracts and Severability of the Arbitration Clause in ...
...the use of inaccurate presumptions and rules. By comparison, approaches employing “transnational principles” such as that adopted in modern American federal practice, or in France, as with Gary Born’s advocacy...
Resolving the Difficulties of Determining What Law Governs the Validity ...
...Indian Model BIT (2015). In more overt practice, Colombia has steadily employed joint interpretative statements over the past few years via the Colombia-France Joint Interpretative Statement (2014), the Colombia-Israel Joint...
Bangladesh’s Regime Change – The India-Bangladesh BIT (2009) and the ...
...issue of the “de-nationalization” of the arbitral proceedings has now most prominently been represented in an eminent opus which was published in 1999—in the English language—in France. This opus is...