Part II Legal Framework: Courts, Statutes and Treaties, D The Architecture of Arbitration, 4 The International Currency of Awards

No discussion of the interaction of courts and arbitrators would be complete without mention of the role of the New York Convention. In 137 countries,1 agreements to arbitrate are enforced under the Convention on the Recognition and Enforcement of Foreign Arbitral Awards.2 Usually called the “New York Convention” by virtue of its city of adoption (or sometimes the “United Nations Convention” after the sponsoring organization), this treaty implements business managers’ agreements to waive recourse to otherwise competent national courts in favor of binding private...