Introduction

The interaction of the provisions of European Community competition law ( EC competition law ) with the arbitral process has been the object of much debate. In particular, the question has arisen whether a state court may annul an arbitral award which does not comply with EC competition law. In a major decision in the case of Eco Swiss v. Benetton[1], the European Court of Justice ( ECJ ) had held that EC competition law is part of the rules of public policy of the Member States within the meaning of Article V(2)(b) of the New York Convention ...