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Switzerland (Geneva and Zurich)

15 November 2018

Law Framework The Swiss PIL Act is a concise law that is readily accessible to local and foreign practitioners, and that promotes flexibility across the range of types of arbitration. Arbitration agreements are accepted as valid under either the governing law or the law of the seat. The Act, which is 28 years’ old, is under review to ensure Switzerland preserves is reputation for excellence in arbitration legislation.


15 November 2018

Law Framework/Limiting intervention Singapore has a modern, effective and arbitration-friendly legislative framework that is updated regularly to reflect the best practices around the world and to embrace developments such as third-party funding. The legislation maximizes judicial support and minimizes judicial interference. However, the review process, including challenges to awards, enforcement proceedings, and the appeals from the first instance decisions can take an unexpectedly long time.

New York

15 November 2018

Law Framework The Federal Arbitration Act is old (dating from 1925) and has required considerable jurisprudential elaboration to articulate its principles and keep pace with international standards. The challenge of navigating this extensive jurisprudence, for local and foreign counsel alike, is currently being addressed by the American Law Institute Restatement project. Despite the considerable value of the Restatement, it remains unclear whether it can achieve a result comparable to the adoption of a modern arbitration law, such as one based on the Model Law.


15 November 2018

Law Framework Paris enjoys high regard for its clear, modern and well-developed legislative framework, favourable to arbitration. The 2011 Amendments to the Code of Civil Procedure have bought additional balance and clarity to this framework.


15 November 2018

Law Framework The English Arbitration Act is regarded by many as an excellent legislative framework that promotes certainty and party autonomy. However, the legislation has been in force for more than 20 years and some have suggested that maintaining a distinctive legislative framework (rather than, for example, adopting the Model Law) makes London more challenging for non-English trained lawyers to navigate. Unusual features, such as the rights of appeal on questions of law, that may not be obvious to newcomers, are as a rule handled sensibly by the courts, but users should be aware of the time and cost of satellite court proceedings that can occur under the Act.

Hong Kong

15 November 2018

Law Framework The Hong Kong Arbitration Ordinance is founded closely on the UNCITRAL Model Law, including its 2006 amendments. The Ordinance is a well-structured example of arbitration legislation that contains arbitration-friendly provisions to supplement the Model Law.


24 July 2018