Introduction

Commercial parties choose to resolve their disputes by international arbitration for many reasons, including greater confidentiality, a neutral forum, and increased control over the selection of decision-makers. Until recently, however, parties were required to go to national courts to request interim measures of protection-such as security, asset freezes, or orders for the protection of evidence-before the constitution of an arbitral tribunal. In response to a perceived need for a mechanism for awarding interim relief within the arbitral system itself (rather than national ...