Comparing the Federal Arbitration Act and the UNCITRAL Model Law on International Commercial Arbitration
Comparing the Federal Arbitration Act and the UNCITRAL Model Law on International Commercial Arbitration, in INTERNATIONAL ARBITRATION IN THE UNITED STATES (Laurence Shore, Lawrence Schaner, Mara Senn, Tai-Heng Cheng, & Jenelle La Chuisa eds., Wolters Kluwer, 2017)
Posted: 3 Oct 2017 Last revised: 16 Jul 2022
Date Written: December 1, 2017
The United States (U.S.) Federal Arbitration Act (the “FAA”) and the United Nations Commission on International Trade Law (UNCITRAL) Model Law on International Commercial Arbitration (the “Model Law”) are two of the main sources of legislative guidance on international arbitration procedure and the enforcement of arbitral awards in the U.S. State arbitration statutes represent a third category of arbitration legislation that may apply to international commercial arbitrations seated or enforced in the U.S. The FAA always applies and the UNCITRAL Model Law may apply to arbitrations seated in the U.S., depending on the location of the seat of arbitration or the place of enforcement of the arbitral award. This book chapter compares the key elements of the FAA and the Model Law.
Keywords: international arbitration, federal arbitration act, arbitration, UNCITRAL, UNCITRAL Model Law
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