Abstract

This article looks at the United Nations Convention on the Recognition and Enforcement of Foreign Arbitral Awards of 1958 ("New York Convention" or "Convention"). The paper argues that the New York Convention has succeeded because of compliance and application by national courts and this success is especially vivid in United States federal courts. In the U.S., federal courts have routinely applied the Convention in recognizing and enforcing international commercial arbitral awards. The article illustrates this success by showing how courts fill gaps by applying contract principles to ...