News & Analysis as of

New York Convention

Pillsbury - Policyholder Pulse blog

Untying the Gordian Knot: The Second Circuit (Re)joins the Fray of Reverse Preemption of International Arbitration Provisions in...

The Second Circuit Court of Appeals has weighed in (again) on a still unsettled issue in the realm of insurance law: whether arbitration provisions in insurance policies issued by foreign insurers are enforceable...more

Foley & Lardner LLP

Second Circuit Holds New York Convention is Self-Executing and Not Preempted by McCarran Ferguson Act

Foley & Lardner LLP on

On May 8, 2025, United States Court of Appeals for the Second Circuit held, in Certain Underwriters at Lloyd’s, London v. 3131 Veterans Blvd LLC, and Certain Underwriters at Lloyd’s, London v. Mpire Properties LLC, Docket...more

Kennedys

International arbitration update: New York Convention not reverse preempted by state law

Kennedys on

In Certain Underwriters at Lloyds, London v. 3131 Veterans BLVD, LLC, the United States Court of Appeals for the Second Circuit held that Article II Section 3 of the New York Convention is self-executing and not...more

Jenner & Block

Client Alert: English High Court Confirms That India’s Ratification of the New York Convention Was Not a Waiver of Its Sovereign...

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The threshold for challenging awards and their enforcement in the UK remains high, a key reason why London remains one of the busiest arbitration venues in the world and a key jurisdiction for the enforcement of arbitral...more

Morrison & Foerster LLP

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

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

White & Case LLP

English Court issues landmark decision on state immunity and enforcement

White & Case LLP on

In a landmark victory for the Republic of India, the Commercial Court has held that India did not waive its state immunity in relation to the enforcement of two bilateral investment treaty awards solely by reason of its...more

Carlton Fields

Fourth Circuit Upholds Confirmation of Hong Kong Arbitration Award

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The Fourth Circuit Court of Appeals recently rejected challenges to a district court’s decision to confirm a Hong Kong arbitration award, including arguments that confirming the award violated public policy and international...more

Carey Olsen

Bermuda Insurance Litigation Guide 2024 (Chambers)

Carey Olsen on

Bermuda is a British Overseas Territory. The modern legal system of Bermuda is established by the Bermuda Constitution Order 1968, an Order in Council of the United Kingdom that established the Supreme Court as the primary...more

WilmerHale

Nonarbitrability and Mandatory Rules: Brothers, Not Twins

WilmerHale on

Notwithstanding the lack of clear legislative intent, Belgian judges have unilaterally prohibited the arbitration of exclusive distribution disputes, unless a specific Belgian pro-distributor statute was applied or unless...more

Jones Day

D.C. Circuit Allows Challenge to Counsel's Authority to Enforce International Arbitration Award

Jones Day on

The D.C. Circuit has approved a backdoor challenge to the validity of an international arbitration award, finding that a challenge to counsel's authority to enforce an award can never be forfeited....more

Vinson & Elkins LLP

Guide to Arbitral Institutions and the Seat of Arbitration in Hong Kong

Vinson & Elkins LLP on

When parties plan to resolve disputes by arbitration, there are several key considerations regarding procedure. In the second of a multi-part series, we look at two key features to consider when drafting (and applying) your...more

A&O Shearman

Jurisdictional challenges to enjoining or staying international arbitrations in US courts

A&O Shearman on

The U.S. District Court for the District of Delawares recent decision in Landbridge Port Services (Hong Kong) Ltd. v. Notarc Port Investment LLC further deepens the split among U.S. federal courts regarding jurisdiction under...more

Carlton Fields

Court Holds Federal Law Governs FAA Arbitration Dispute Related to Surplus Lines Insurance Contract, Compels Arbitration Under...

Carlton Fields on

Harbor Homeowner’s Association Inc. sued its insurers in Louisiana state court seeking to recover damages allegedly caused by the insurers’ failure to pay claims related to Hurricane Ida. The insurers removed to federal...more

Conyers

Navigating Defences and the Burden of Proof on the New York Convention Chessboard: The BVI Court’s Approach

Conyers on

In its recent decision in BVIHC(COM) 2022/0169 Qu Haiping v Window of Trade International Limited and Ors, the BVI Court considered the question of the burden of proof and defences that a defendant can invoke when resisting...more

Morrison & Foerster LLP

The Federal Republic of Nigeria v P&ID – Renewed scrutiny of IA

Morrison & Foerster LLP on

On 23 October 2023, the English Commercial Court published its much-anticipated judgment in The Federal Republic of Nigeria v Process & Industrial Developments Limited [2023] EWHC 2638 (Comm). The Court found in favour of the...more

Carlton Fields

SDNY Confirms Arbitration Award Under New York Convention

Carlton Fields on

In Exclusive Trim Inc. v. Kastamonu Romania, S.A., the U.S. District Court for the Southern District of New York granted a petition to confirm and enforce a foreign arbitration award issued in an arbitration held before the...more

Proskauer - Minding Your Business

Federal Court Upholds Arbitral Award Despite Failures to Disclose Potential Bias

The Eleventh Circuit upheld an arbitral award last month despite the arbitrators’ failure to make certain disclosures regarding potential sources of bias. The litigation involved a dispute between the Panama Canal Authority,...more

Carlton Fields

Court Follows Fifth Circuit Precedent in Enforcing Unsigned Insurance Arbitration Agreement Under New York Convention

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The insured argued that the arbitration agreement at issue was not enforceable under the Convention on the Recognition and Enforcement of Foreign Arbitral Awards because the agreement was not signed by both parties and...more

Hinshaw & Culbertson - Insights for Insurers

The Second Circuit May Well Reconsider Reverse-Preemption of The New York Convention by the McCarran-Ferguson Act

A significant number of states prohibit or restrict the arbitration of disputes between an insurer and its policyholder and/or preclude the inclusion of arbitral provisions in insurance policies.The McCarran-Ferguson Act...more

Carlton Fields

First Circuit Holds That New York Convention Preempts Puerto Rican Law

Carlton Fields on

The First Circuit Court of Appeals has held that the New York Convention applies to an insurance arbitration dispute between a Puerto Rican company and Lloyd’s of London and that the convention preempts a Puerto Rican law...more

Foley & Lardner LLP

10th Circ. Highlights US Court Discretion On Arbitral Awards

Foley & Lardner LLP on

In Compañía de Inversiones Mercantiles SA v. Grupo Cementos de Chihuahua SAB de CV, a panel of judges on the U.S. Court of Appeals for the Tenth Circuitrecently held in a 2-1 decision that the U.S. District Court for the...more

Hogan Lovells

Saudi Center for Commercial Arbitration publishes updated arbitration rules

Hogan Lovells on

Saudi Arabia has taken a number of steps over recent years to modernize its arbitration laws, as well as establishing the Saudi Center for Commercial Arbitration (the "SCCA") in 2016. This is part of the Kingdom's vision of...more

A&O Shearman

The U.S. Eleventh Circuit Court of Appeals en banc overturns Industrial Risk and INPROSTA

A&O Shearman on

Last year, we wrote about precedent in the U.S. Court of Appeals for the Eleventh Circuit holding that international arbitration awards issued in the U.S. and encompassed by the New York Convention can be vacated only under...more

Foley & Lardner LLP

Enforcement of Annulled Foreign Arbitral Awards in the U.S.

Foley & Lardner LLP on

In Compañía de Inversiones Mercantiles SA v. Grupo Cementos de Chihuahua SAB de CV, 58 F.4th 429 (10th Cir. 2023) (“CIMSA v. GCC”), a panel of judges on the Tenth Circuit held in a 2-1 decision that the U.S. District Court...more

Shook, Hardy & Bacon L.L.P.

Eleventh Circuit Overhauls the Grounds Under Which an International Arbitral Award can be Vacated, Annulled, or Set Aside

Key points - In a major shift, the Eleventh Circuit has overruled prior jurisprudence and changed the grounds for vacatur (also called annulment or set-aside) of international arbitration awards, aligning with decisions...more

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