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Choice of Law for Enforcement of Arbitral Awards – A Return to the Lex Loci Arbitri?

Nicholas Poon

(2012) 24 SAcLJ 113

Abstract:
Traditionally, conflict of laws does not feature prominently in international commercial arbitration. However, as more international cross-border complex disputes are resolved by arbitration, conflict of laws is likely to be of greater importance. This article focuses on the relevance and impact of choice of law in international commercial arbitration, with particular emphasis on the importance of choice of law in enforceability of arbitral awards.