Introduction

There are effectively two regimes for the finality and enforcement of Investment Awards: those under the ICSID Convention route which embrace a completely self-contained regulatory scheme for limited review and enforcement and rule based awards arising from the application of procedural rules, such as the UNCITRAL Model Law or Rules or those of the ICC, with issues of review determined by the applicable domestic law and enforcement turning on the application of the New York Convention of 1958 as also applied by state laws. In 1985 UNCITRAL hitched its star to the New ...