International commercial arbitration has become increasingly popular in recent years in large part because it offers quicker and more convenient dispute resolution than litigation in a foreign nation. Nonetheless, arbitration, like litigation, presents knotty choice of law problems. This Article examines a variety of approaches currently used by arbitrators to select the law which will govern arbitration procedure. The competing interests of the international business community and the various sovereign nations seeking to control international arbitration are discussed.
The Choice of Applicable Law in International Arbitration,
9 Hastings Int'l & Comp. L. Rev. 235
Available at: https://repository.uchastings.edu/hastings_international_comparative_law_review/vol9/iss2/2