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The UAE has made progress: its courts tend to recognise the decisions of foreign arbitral tribunals.
Whether a foreign arbitral award can be recognised and enforced by the Chinese courts has always been on the top of foreign parties' list of concerns.
See James M. Zimmerman, "Recognition and Enforcement of Arbitral Awards in the United States" (Website) (Zimmerman), for a discussion of the applicable law for recognition and enforcement of foreign arbitral awards.
An arbitration court, as an example, issues an award that is enforceable in ordinary court according to the Convention on the Recognition and Enforcement of Foreign Arbitral Rewards ("New York Convention" from 1958).
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Where a foreign arbitration clause is involved, the Federal Arbitration Act should be construed with due regard for the doctrine that the "emphatic federal policy in favor of arbitral dispute resolution..
4. Conflict of Laws M.H. ten Wolde. 5. Enforcement of Foreign Judgments and Arbitral Awards M.R. Wijnholt.
"This incident [Duterte's remark] graphically explains Philippine foreign policy on the South China Sea dispute after the arbitral ruling," Carpio lamented during a high-profile symposium marking the first anniversary of the arbitration award.
vindicate" its federal statutory rights in an arbitral forum permitted courts to invalidate arbitration agreements.
India is seeking to become the world's newest international arbitration hub by establishing a new arbitral center in Mumbai.
In January, 2014, Ecuador filed a petition in the District Court of the Hague (the legal seat of the BIT arbitration) to set aside the above-mentioned arbitral awards.
And Duterte's controversial remarks, particularly the late 2016 announcement that he "will set aside the arbitral ruling," have been a source of concern among those who view Philippine foreign policy as too acquiescent towards China.
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