…public policy under Brazilian law. In addition to these well-known provisions inspired by the New York Convention, the STJ’s internal rules state that a foreign judgment, including a foreign arbitral…

…allow for consolidation. Ensuring as a preliminary matter that the mechanism for consolidation and any waiver provisions in the institutional rules or national arbitration laws adopted accords with the parties’…

Professor Stacie Strong has noted on this blog that “[c]ritics of international arbitration often express concerns about the quality of legal reasoning in arbitration, even though conventional wisdom…suggests that international…

…where the arbitration took place” (under Article 34(2)(a)(iv) of the UNCITRAL Model Law on International Commercial Arbitration (“Model Law”) for awards emanating from international arbitration; section 48(1)(a)(v) of the Singapore…

…do not apply as such to this international arbitration. The Arbitral Tribunal further notes that neither the Finnish Arbitration Act nor the FAI Rules contain provisions similar to the FPC….