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Morrison & Foerster LLP

English High Court Clarifies Sovereign Immunity: Ratification of New York Convention Not a Waiver

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English High Court determines that ratification of the New York Convention on the Recognition and Enforcement of Arbitral Awards does not constitute prior written agreement to waive sovereign immunity....more

K&L Gates LLP

If You Cannot Enforce a Judgment in Your Jurisdiction, You May Still Be Able to Enforce in England

K&L Gates LLP on

In the recent case of Invest Bank PSC v. Ahmad Mohammed El-Husseini and Others [2023] 2302 (Comm), the High Court of England and Wales determined that two monetary judgments issued in the United Arab Emirates (UAE) could be...more

Akin Gump Strauss Hauer & Feld LLP

The Law of an Arbitration Agreement: Is it the Law of the Seat or the Law of the Underlying Contract? – Paris Contradicts London

Akin Gump Strauss Hauer & Feld LLP on

If there is no express law of the arbitration agreement, the law with which that agreement has its closest and most real connection is either the law of the underlying contract or the law of the seat of the arbitration. In...more

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