Introduction

Much has been written about applicable law issues in international economic arbitration. The main focus of these writings has been on conflict of laws problems. The choice-of-law provisions of modern arbitration laws and rules authorize the arbitrators to free themselves from the conflict of laws rules of the jurisdiction where the arbitration has its seat, thus confirming the rule that international arbitrators have no lex fori . Instead, they may apply the choice-of-law rules they deem appropriate or determine the applicable substantive law without reference to any ...