There are many reasons that parties to international business transaction often decide to resolve their disputes through international arbitration, one of which is the knowledge and comfort that the United Nations Convention on the Recognition and Enforcement of Foreign Arbitral Awards, June 10, 1958, 21 U.S.T. 2517 (commonly known as the New York Convention) is a widely adopted treaty that brings a relative amount of ease to enforcing international arbitration awards. The Convention, however, includes, as it must, a number of mandatory requirements for invoking its coverage.
The same is true for the Federal Arbitration Act (FAA), which sets forth grounds for challenging an arbitration award in domestic arbitrations, but which grounds can also apply where the New York Convention governs and the United States is the so-called “primary jurisdiction.”
