Author: Rebecca Lamb Published: October 2021 Jurisdictions: International France United States Topics: Investment Disputes Insurance ICSID Nationality of Parties ABSTRACT The International Center for Settlement of Investment Disputes (ICSID) was...
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...Intern at the United Nations Commission on International Trade Law (UNICTRAL), United Nations. Vienna, Austria. This paper does not necessarily reflect the views or opinions of UNCITRAL or the United...
Reviewing Trends and Proposals to Recognize Oral Agreements to Arbitrate ...
...are the primary factors to determine the governing law of the arbitration agreement clause. Position in Favor of the United Kingdom and Singapore United Kingdom The Enka v. Chubb...
Reinforcing the Position on Governing Law of Arbitration Agreement: An ...
Author: Marc J. Goldstein* Published: September 2019 Jurisdictions: International Panama United States Topics: Agreement to Arbitrate Third Parties in Arbitral Proceedings Multiple Parties Formal Requirements New York Convention Enforcement of...
Deciphering De Gusa: The Enforcement in U.S. Courts of International ...
...by States or communities of States may seem to be paradoxical. Although arbitration has no significant territorial ties with States, it may be affected by their domestic or regional laws,...
The Extraterritoriality of Laws in International Arbitration – Vol. 29 ...
Author: Charles H. Brower II* Published: October 2016 Description: In October 2015, the United States completed negotiations for the Trans-Pacific Partnership (“TPP”), a free trade agreement among twelve Pacific Rim...
Trans-Pacific Partnership: Continuity and Breakthroughs in U.S. Investment Treaty Practice ...
...the Washington Convention on the Settlement of Investment Disputes Between States and Nationals of Other States (1965) (“ICSID Convention”) or the 2021 Arbitration Rules of the International Chamber of Commerce...
The Brazil-Nigeria Samba: From Partners in Business to Parties in ...
...decision of the seat court rather than invoke transnational issue estoppel, unless there are exceptional circumstances. Courts in the United States also apply a “light touch” approach when considering substantive...
SGCA’s Ruling in Republic of India v. Deutsche Telekom: The ...
Author: Tietie Zhang* Published: November 2017 Jurisdictions: China United States Topics: Public Policy Favoring Arbitration Jurisdiction and Powers of the Courts in Matters of Arbitration Generally Judicial Decisions Description: I....
Judicial Sovereignty and Public Policy under Chinese Arbitration Law – ...
Author: Harout Jack Samra* Published: October 2010 Jurisdiction: United States Topics: Law Applicable to the Merits Law Applicable to Procedure Enforceability New York Convention Description: I. INTRODUCTION Over the last...
Two to Tango: Domestic Grounds for Vacatur Under the New ...
...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...
Confidentiality Concerns in Arbitration Disputes: Implementation of Confidentiality in Courts ...
...with the following examples: Although in Switzerland, Italy, France and Sweden, privilege does not extend to in-house counsels, it does in the United States and the United Kingdom. With regard...