International arbitration

International arbitration is arbitration between companies or individuals in different states, usually by including a provision for future disputes in a contract.(International Center for Dispute Resolution)(ICSID)(International Center for Dispute Resolution)(ICDR)(International Center for Dispute Resolution)(CAM-CCBC) International arbitration is arbitration between companies or individuals in different states, usually by including a provision for future disputes in a contract. The predominant system of rules is the UNCITRAL Arbitration Rules, as well as the United Nations Convention on the Recognition and Enforcement of Foreign Arbitral Awards of 1958 (the 'New York Convention'). The International Centre for the Settlement of Investment Disputes (ICSID) also handles arbitration, but it is particularly focused on investor-state dispute settlement and hears relatively few cases. The New York Convention was drafted under the auspices of the United Nations and has been ratified by more than 150 countries, including most major countries involved in significant international trade and economic transactions. The New York Convention requires the states that have ratified it to recognize and enforce international arbitration agreements and foreign arbitral awards issued in other contracting states, subject to certain limited exceptions. These provisions of the New York Convention, together with the large number of contracting states, have created an international legal regime that significantly favors the enforcement of international arbitration agreements and awards. It was preceded by the 1927 Convention on the Execution of Foreign Arbitral Awards in Geneva. International arbitration allows the parties to avoid local court procedures. International arbitration has different rules than domestic arbitration, and has its own non-country-specific standards of ethical conduct. The process may be more limited than typical litigation and forms a hybrid between the common law and civil law legal systems. For example, the International Bar Association (IBA)'s Rules on the Taking of Evidence in International Commercial Arbitration, revised in 2010, do not adopt common law broad disclosure procedures (discovery) or follow the civil law in eliminating entirely the ability of engaging in some disclosure-related practices. The IBA Rules blend common and civil systems so that parties may narrowly tailor disclosure to the agreement's particular subject matter. David Rivkin, who chaired the committee that drafted the rules, has noted that the wide adoption of these rules in international arbitration has led in practice to an unexpected use by common law practitioners to limit disclosure and by civil law practitioners to expand it. The rules can be further impacted by arbitral rules that may be agreed between the parties. Most countries, especially in the developed world, are signatories of the New York Convention. Consequently, judgements can be enforced across the world. The New York Convention, more formally known as the United Nations Convention on the Recognition and Enforcement of Foreign Arbitral Awards, provides for court recognition and enforcement of foreign arbitration decisions, allowing arbitration proceedings to piggyback on the authority of domestic jurisdictions across the world. In contrast, there is no equivalent treaty for the international recognition of court decisions with a large membership although the Hague Convention of 30 June 2005 on Choice of Court Agreements entered into force in 2015 for the European Union and Mexico. Similarly, no equivalent treaty exists so far for the international recognition of settlements achieved in mediation or conciliation:so far, a meeting of the UNCITRAL Working Group II in New York has taken place in February 2015 subsequent to a US proposal for that working group to develop a convention on the enforcement of conciliated settlement agreements for international commercial disputes. Within the EU, the enforceability of mediation agreements is ruled by Directive 2008/52/EC.