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Decoding International Arbitration

InHouseOps

Remember, these are cases that could involve parties from common law and civil law countries. In fact, we include such language in the award because in the New York Convention, for example, the US has taken a reservation to that treaty that it will enforce the awards based on reciprocity.

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Second edition of The Hague Academy of International Law’s Advanced Course in Hong Kong on “Recognition and Enforcement of Foreign Judgments in Civil or Commercial Matters: Judgments Convention”

Conflict of Laws

10), which according to Franzina was designed not primarily with civil law systems in mind, but rather for common law jurisdictions, who were assumed to have difficulties in asserting the public policy exception (Art. 301 Civil Procedure Law (2023). 7 (1) lit. 2 HCCH 1958 until Art.