In any arbitration, the parties’ choice of seat normally determines the legal regime under which an arbitration is conducted and any award is enforced. Accustomed to the international “seat standard,” one might think that an ICC arbitration award rendered in China, for example, would be subject to confirmation or set aside in Chinese court pursuant…

In Part I of our post, we discussed the long-standing uncertainties existing in China about what legal regime governs arbitrations administered by foreign arbitral institutions. We also introduced the recent, groundbreaking ruling by the Guangzhou Court in Brentwood v. Guangdong Fa’anlong. Here in Part II, we further discuss whether China might adopt the internationally-accepted “seat…