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A. LEGISLATION AND RULES A.1 Legislation The French Parliament is considering reforming French arbitration law, the current version of which was enacted in 2011. On 12 November 2024, a working group established by the French Ministry of Justice was assigned to explore ways to reform French arbitration law. This working group is led by Thomas Clay, an arbitrator, lawyer, and law professor, along with Judge François Ancel. The goal of this reform is to modernize…

A. LEGISLATION AND RULES A.1 Legislation The regulations governing arbitration proceedings in Italy are found in the Italian Code of Civil Procedure (ICCP). Specifically, domestic and international arbitration are regulated by ICCP articles 806 to 832, while the recognition and enforcement of foreign awards are regulated in ICCP articles 839 and 840. On 28 February 2023, the “Cartabia Reform” (“Reform”), enacted by the Italian Legislative Decree No. 149 of 2022 (“Decree”), entered into force, introducing…

Introduction The UK Supreme Court has now provided its reasons for an earlier decision to uphold a decision by the English Court of Appeal (“CoA”) in UniCredit Bank GmbH v RusChemAlliance [2024] EWCA Civ 64, in which the CoA granted an anti-suit injunction (“ASI”) against RusChemAlliance LLC (“RCA“), a Russian entity in which Gazprom has a direct interest, despite the foreign seat of the arbitration (in Paris). The CoA had overturned the decision of the…

In a decision of April 3, 2024, the Swiss Federal Supreme Court (“SFSC”) dismissed an application by Spain for an annulment of an arbitral award issued by an ad hoc-arbitral tribunal seated in Geneva. The arbitral tribunal had held that Spain had failed to accord fair and equitable treatment to a French company which had acquired and developed, through Spanish subsidiaries, twelve photovoltaic installations in Spain, and had awarded to the French investor EUR 29…