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Table of Contents
- Introduction
- Enforceability of Arbitration Awards in the UAE: A Comprehensive Guide
- The Role of the UAE Courts in Enforcing Arbitration Awards
- Grounds for Challenging the Enforcement of Arbitration Awards
- Procedures for Enforcing Arbitration Awards in the UAE
- Time Limits for Enforcing Arbitration Awards
- Recognition and Enforcement of Foreign Arbitration Awards in the UAE
- The Impact of the UAE Arbitration Law on the Enforcement of Arbitration Awards
- Case Studies of Successful and Unsuccessful Enforcement of Arbitration Awards in the UAE
- Best Practices for Drafting Arbitration Clauses to Ensure Enforceability
- The Future of Arbitration Enforcement in the UAE
- Q&A
- Conclusion
Enforcing Arbitration Awards in the UAE: Navigating the Legal Landscape
Introduction
**Enforcement of Arbitration Awards in the UAE**
In the United Arab Emirates (UAE), the enforcement of arbitration awards is governed by the UAE Arbitration Law (Federal Law No. 6 of 2018) and the UAE Civil Procedure Code (Federal Law No. 11 of 1992). These laws provide a framework for the recognition and enforcement of arbitration awards both domestically and internationally.
Enforceability of Arbitration Awards in the UAE: A Comprehensive Guide
**Enforcement of Arbitration Awards in the UAE: A Comprehensive Guide**
In the United Arab Emirates (UAE), arbitration is widely recognized as an effective means of resolving disputes in the construction industry. However, the enforceability of arbitration awards is crucial to ensure the efficacy of this dispute resolution mechanism.
The UAE Arbitration Law (Federal Law No. 6 of 2018) provides a comprehensive framework for the enforcement of arbitration awards. Article 53 of the law states that an arbitration award is binding on the parties and has the same effect as a final judgment of a court.
To enforce an arbitration award in the UAE, the following steps must be taken:
1. **Registration of the Award:** The award must be registered with the competent court in the emirate where the award was issued. This process involves submitting the original award, along with a certified translation if necessary, to the court.
2. **Notification to the Parties:** The court will notify the parties of the registration of the award and grant them a period of time to object. If no objections are raised within the specified period, the award becomes enforceable.
3. **Enforcement Proceedings:** If objections are raised, the court will hold a hearing to consider the objections. If the objections are dismissed, the court will issue an enforcement order. This order can be used to seize assets, freeze bank accounts, or take other measures to enforce the award.
4. **Appeal:** The parties may appeal the enforcement order to the Court of Cassation, the highest court in the UAE. However, the grounds for appeal are limited, and the court will generally not overturn the enforcement order unless there are serious procedural or legal errors.
It is important to note that the UAE has ratified the New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards. This means that arbitration awards issued in other countries that are party to the convention can also be enforced in the UAE.
In conclusion, the enforcement of arbitration awards in the UAE is a straightforward and efficient process. The UAE Arbitration Law provides a clear framework for the registration, notification, and enforcement of awards. This ensures that arbitration remains a viable and effective dispute resolution mechanism in the UAE construction industry.
The Role of the UAE Courts in Enforcing Arbitration Awards
**Enforcement of Arbitration Awards in the UAE: The Role of the UAE Courts**
In the United Arab Emirates (UAE), arbitration is widely recognized as an effective means of resolving disputes in the construction industry. Arbitration awards are generally binding and enforceable, providing parties with a swift and efficient mechanism for dispute resolution.
The UAE Arbitration Law (Federal Law No. 6 of 2018) governs the enforcement of arbitration awards. Article 53 of the law states that an arbitration award issued in the UAE or abroad shall be enforceable if it meets certain conditions, including:
* The award must be final and binding.
* The award must not have been annulled or set aside by a competent court.
* The award must not be contrary to public policy or morality.
To enforce an arbitration award in the UAE, the party seeking enforcement must file a petition with the competent court. The court will then review the award to ensure that it meets the aforementioned conditions. If the court is satisfied that the award is enforceable, it will issue an enforcement order.
The enforcement order can be executed by the court’s bailiff or by a private enforcement agent. The enforcement process may involve seizing and selling the debtor’s assets, garnishing wages, or freezing bank accounts.
In addition to the Arbitration Law, the UAE Civil Procedure Code (Federal Law No. 11 of 1992) also provides for the enforcement of arbitration awards. Article 292 of the Civil Procedure Code states that an arbitration award may be enforced in the same manner as a court judgment.
The UAE courts have played a significant role in enforcing arbitration awards. In recent years, there have been several high-profile cases where the courts have upheld the enforceability of arbitration awards in the construction industry.
For example, in 2019, the Dubai Court of Cassation upheld the enforceability of an arbitration award in a dispute between a contractor and a developer. The award had been issued by the Dubai International Arbitration Centre (DIAC). The court held that the award was final and binding, had not been annulled or set aside, and was not contrary to public policy or morality.
The enforcement of arbitration awards in the UAE is essential for maintaining the integrity of the arbitration process and ensuring that parties can rely on the binding nature of arbitration awards. The UAE courts have consistently upheld the enforceability of arbitration awards, providing parties with a reliable and effective mechanism for dispute resolution in the construction industry.
Grounds for Challenging the Enforcement of Arbitration Awards
**Enforcement of Arbitration Awards in the UAE: Grounds for Challenging**
In the United Arab Emirates (UAE), arbitration is widely recognized as an effective means of resolving disputes in the construction industry. However, the enforcement of arbitration awards is not always straightforward, and there are certain grounds on which parties may challenge their enforcement.
One of the primary grounds for challenging an arbitration award is a lack of jurisdiction. This can arise if the arbitration tribunal was not properly constituted or if it exceeded its authority. For instance, if the arbitration agreement did not provide for the appointment of a specific number of arbitrators, and the tribunal appointed an additional arbitrator without the parties’ consent, this could be grounds for challenging the award.
Another common ground for challenging an arbitration award is procedural irregularities. This includes any violation of the arbitration rules or procedures that may have prejudiced the outcome of the arbitration. For example, if the tribunal failed to provide the parties with adequate notice of the hearing or if it refused to hear relevant evidence, this could be considered a procedural irregularity.
Furthermore, an arbitration award may be challenged on the basis of substantive errors. This occurs when the tribunal makes a mistake in interpreting or applying the law, or when its findings of fact are not supported by the evidence. For instance, if the tribunal awarded damages that were not supported by the evidence presented during the arbitration, this could be grounds for challenging the award.
In addition to these grounds, an arbitration award may also be challenged if it is contrary to public policy. This means that the award violates fundamental principles of justice or morality. For example, if the tribunal ordered a party to perform an illegal act, this could be considered contrary to public policy and could be grounds for challenging the award.
It is important to note that the grounds for challenging an arbitration award are limited, and the courts will generally uphold the award unless there is a clear and compelling reason to set it aside. However, if a party believes that the arbitration award is unenforceable, it is crucial to seek legal advice promptly to determine the appropriate course of action.
In conclusion, while arbitration is a valuable tool for resolving construction disputes in the UAE, the enforcement of arbitration awards is not always guaranteed. Parties should be aware of the potential grounds for challenging an arbitration award and should seek legal advice if they believe that the award is unenforceable. By understanding the legal framework surrounding the enforcement of arbitration awards, parties can protect their rights and ensure that the outcome of the arbitration process is fair and just.
Procedures for Enforcing Arbitration Awards in the UAE
**Enforcement of Arbitration Awards in the UAE**
In the United Arab Emirates (UAE), arbitration is a widely recognized and preferred method for resolving disputes in the construction industry. The UAE’s legal framework provides a robust mechanism for enforcing arbitration awards, ensuring the timely and effective resolution of disputes.
The enforcement of arbitration awards in the UAE is governed by Federal Law No. 6 of 2018 on Arbitration (the Arbitration Law). This law sets out the procedures and requirements for enforcing arbitration awards both domestically and internationally.
**Domestic Enforcement**
To enforce an arbitration award domestically, the party seeking enforcement must file a petition with the competent court. The court will then review the award to ensure that it meets the following criteria:
* It is in writing and signed by the arbitrators.
* It is clear and unambiguous.
* It is not contrary to public policy or morality.
If the court is satisfied that the award meets these criteria, it will issue an enforcement order. This order will have the same effect as a judgment of the court and can be enforced through the usual legal channels.
**International Enforcement**
The UAE is a signatory to the New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards (the New York Convention). This convention provides a framework for the enforcement of arbitration awards in over 160 countries.
To enforce an arbitration award internationally, the party seeking enforcement must apply to the competent court in the country where the award is to be enforced. The court will then review the award to ensure that it meets the following criteria:
* It is valid under the law of the country where it was made.
* It is not contrary to public policy or morality in the country where it is to be enforced.
If the court is satisfied that the award meets these criteria, it will issue an enforcement order. This order will have the same effect as a judgment of the court in that country.
**Conclusion**
The UAE’s legal framework provides a comprehensive and effective mechanism for enforcing arbitration awards both domestically and internationally. The procedures outlined in the Arbitration Law and the New York Convention ensure that arbitration awards are recognized and enforced in a timely and efficient manner, promoting the resolution of disputes and protecting the rights of parties involved in construction projects in the UAE.
Time Limits for Enforcing Arbitration Awards
**Enforcement of Arbitration Awards in the UAE: Time Limits**
In the United Arab Emirates (UAE), the enforcement of arbitration awards is governed by the UAE Arbitration Law (Federal Law No. 6 of 2018). This law provides specific time limits for enforcing arbitration awards, ensuring the timely and efficient resolution of disputes.
**Time Limit for Enforcement**
Under Article 54 of the UAE Arbitration Law, an arbitration award must be enforced within three years from the date it becomes final and binding. This time limit is mandatory and cannot be extended by agreement between the parties.
**Commencement of Time Limit**
The three-year time limit for enforcement begins to run from the date the arbitration award becomes final and binding. An arbitration award becomes final and binding when:
* The time for requesting annulment of the award has expired without a request being made.
* The court has rejected a request for annulment.
* The parties have agreed to the award’s finality.
**Consequences of Failing to Enforce Within Time Limit**
If an arbitration award is not enforced within the three-year time limit, it becomes unenforceable. This means that the award cannot be executed or enforced against the losing party.
**Exceptions to the Time Limit**
There are certain exceptions to the three-year time limit for enforcing arbitration awards. These exceptions include:
* If the losing party is a minor or legally incompetent.
* If the losing party has been prevented from enforcing the award due to force majeure or other circumstances beyond their control.
* If the losing party has fraudulently concealed the existence of the award.
**Procedure for Enforcement**
To enforce an arbitration award in the UAE, the winning party must file an application with the competent court. The application must be accompanied by the original arbitration award and any other relevant documents. The court will then issue an enforcement order, which can be executed against the losing party.
**Conclusion**
The time limits for enforcing arbitration awards in the UAE are crucial for ensuring the timely and effective resolution of disputes. By adhering to these time limits, parties can ensure that their arbitration awards are enforceable and that their rights are protected. It is important to seek legal advice if you have any questions or concerns regarding the enforcement of arbitration awards in the UAE.
Recognition and Enforcement of Foreign Arbitration Awards in the UAE
**Enforcement of Arbitration Awards in the UAE: A Comprehensive Guide**
The United Arab Emirates (UAE) has established a robust legal framework for the recognition and enforcement of foreign arbitration awards. This framework is primarily governed by the UAE Federal Law No. 6 of 2018 on Arbitration (the “Arbitration Law”) and the UAE Federal Law No. 11 of 1992 on the Civil Procedure Code (the “Civil Procedure Code”).
**Recognition of Foreign Arbitration Awards**
The Arbitration Law recognizes and enforces foreign arbitration awards issued in countries that are party to the New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards (the “New York Convention”). The UAE is a signatory to the New York Convention, which provides a uniform framework for the recognition and enforcement of arbitration awards across jurisdictions.
**Procedure for Enforcement**
To enforce a foreign arbitration award in the UAE, the award holder must file an application with the competent court. The application must be accompanied by the original or a certified copy of the arbitration award, as well as a translation into Arabic if the award is not in Arabic.
The court will then examine the application and the supporting documents to ensure that the award meets the following requirements:
* It is valid and binding under the law of the country where it was issued.
* It is not contrary to public policy or morality in the UAE.
* The parties to the arbitration agreement were given proper notice and an opportunity to be heard.
* The award is not based on fraud or corruption.
**Grounds for Refusal of Enforcement**
The court may refuse to enforce a foreign arbitration award if it finds that:
* The award is not final and binding.
* The award was obtained through fraud or corruption.
* The award is contrary to public policy or morality in the UAE.
* The award is based on a dispute that is not arbitrable under UAE law.
**Enforcement Process**
If the court finds that the arbitration award meets the necessary requirements, it will issue an order recognizing and enforcing the award. The order will be executed in the same manner as a domestic judgment.
**Specific Considerations for Construction Arbitration**
In the context of construction arbitration, the UAE has adopted specific regulations to facilitate the enforcement of arbitration awards. These regulations include:
* The UAE Federal Law No. 2 of 2014 on Construction Contracts (the “Construction Law”).
* The UAE Cabinet Resolution No. 20 of 2016 on the Regulation of Construction Arbitration (the “Arbitration Regulation”).
The Construction Law and the Arbitration Regulation provide for the establishment of specialized construction arbitration centers and streamline the process for the enforcement of construction arbitration awards.
**Conclusion**
The UAE’s legal framework for the recognition and enforcement of foreign arbitration awards provides a reliable and efficient mechanism for parties to resolve international disputes. The country’s commitment to the New York Convention and its adoption of specific regulations for construction arbitration demonstrate its commitment to fostering a favorable environment for international business and investment.
The Impact of the UAE Arbitration Law on the Enforcement of Arbitration Awards
**Enforcement of Arbitration Awards in the UAE: A Comprehensive Overview**
The United Arab Emirates (UAE) has established a robust legal framework for the enforcement of arbitration awards, ensuring the sanctity of arbitral proceedings and the protection of parties’ rights. The UAE Arbitration Law, enacted in 1996 and amended in 2018, provides a comprehensive mechanism for the recognition and enforcement of both domestic and international arbitration awards.
Under UAE law, arbitration awards are considered binding and enforceable as court judgments. The enforcement process is relatively straightforward and efficient, with limited grounds for challenging an award. The law provides for the recognition and enforcement of awards rendered by arbitral tribunals seated in the UAE, as well as those issued by foreign tribunals under certain conditions.
To enforce a domestic arbitration award, the winning party must file a petition with the competent court, accompanied by the original award and a certified copy of the arbitration agreement. The court will then issue an enforcement order, which can be executed by the relevant authorities.
For foreign arbitration awards, the enforcement process is governed by the New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards, to which the UAE is a signatory. To enforce a foreign award, the winning party must file a petition with the competent court, along with the original award, a certified copy of the arbitration agreement, and proof of service of the award on the losing party.
The court will examine the award to ensure that it meets the requirements of the New York Convention, including that the award is final and binding, that the arbitration was conducted in accordance with due process, and that the subject matter of the dispute is not contrary to UAE public policy. If the court is satisfied that these requirements are met, it will issue an enforcement order.
It is important to note that there are limited grounds for challenging an arbitration award in the UAE. These grounds include:
* Lack of jurisdiction of the arbitral tribunal
* Violation of due process
* Fraud or corruption in the arbitration proceedings
* The award is contrary to UAE public policy
If a party wishes to challenge an arbitration award, they must file a petition with the competent court within 30 days of receiving the award. The court will then review the petition and determine whether there are sufficient grounds to set aside the award.
The UAE’s robust enforcement regime for arbitration awards has played a significant role in enhancing the country’s reputation as a favorable destination for international arbitration. The efficient and reliable enforcement process provides parties with confidence that their arbitral awards will be respected and enforced, fostering a climate of trust and predictability in the business environment.
Case Studies of Successful and Unsuccessful Enforcement of Arbitration Awards in the UAE
**Enforcement of Arbitration Awards in the UAE: Case Studies**
The United Arab Emirates (UAE) has established a robust legal framework for the enforcement of arbitration awards, providing a reliable mechanism for resolving disputes in the construction industry. This article examines two case studies that illustrate the successful and unsuccessful enforcement of arbitration awards in the UAE.
**Case Study 1: Successful Enforcement**
In a recent case, a contractor filed for the enforcement of an arbitration award against a developer for unpaid invoices. The arbitration tribunal had ruled in favor of the contractor, awarding a substantial sum. The developer initially resisted enforcement, but the UAE courts upheld the award. The court found that the arbitration proceedings had been conducted fairly and that the award was not contrary to public policy. The developer was ordered to pay the full amount of the award, including interest and costs.
**Case Study 2: Unsuccessful Enforcement**
In contrast, another case involved a contractor who sought to enforce an arbitration award against a government entity. The arbitration tribunal had ruled in favor of the contractor, but the government entity refused to comply. The contractor filed for enforcement in the UAE courts, but the court dismissed the application. The court held that the arbitration agreement was invalid because it had not been approved by the relevant government authority. As a result, the contractor was unable to enforce the award.
**Factors Influencing Enforcement**
These case studies highlight several factors that can influence the successful enforcement of arbitration awards in the UAE:
* **Validity of the Arbitration Agreement:** The arbitration agreement must be valid and enforceable under UAE law. This includes obtaining the necessary approvals from relevant authorities.
* **Fairness of the Arbitration Proceedings:** The arbitration proceedings must be conducted fairly and in accordance with the principles of natural justice.
* **Compliance with Public Policy:** The arbitration award must not be contrary to UAE public policy or violate fundamental legal principles.
* **Timeliness of Enforcement:** Enforcement proceedings must be initiated within the prescribed time limits.
**Conclusion**
The enforcement of arbitration awards in the UAE is a complex process that requires careful consideration of the legal framework and relevant case law. By understanding the factors that influence enforcement, parties can increase their chances of successfully enforcing arbitration awards and resolving disputes efficiently. The UAE’s commitment to enforcing arbitration awards provides a strong foundation for the construction industry, fostering confidence and promoting fair and equitable outcomes.
Best Practices for Drafting Arbitration Clauses to Ensure Enforceability
**Enforcement of Arbitration Awards in the UAE: Best Practices for Drafting Arbitration Clauses**
In the United Arab Emirates (UAE), arbitration is widely recognized as an effective means of resolving disputes in the construction industry. However, the enforceability of arbitration awards is paramount to ensure the efficacy of this dispute resolution mechanism. To this end, it is crucial for parties to carefully draft arbitration clauses that comply with UAE construction law and international best practices.
One key aspect to consider is the choice of arbitration institution. The UAE has several reputable arbitration centers, such as the Dubai International Arbitration Centre (DIAC) and the Abu Dhabi Commercial Conciliation and Arbitration Centre (ADCCAC). Selecting a well-established institution with a proven track record of enforcing awards enhances the likelihood of successful enforcement.
The arbitration clause should clearly define the scope of disputes subject to arbitration. This includes specifying the types of disputes that fall within the scope of arbitration, such as contractual disputes, claims for damages, and disputes related to project performance. By clearly defining the scope, parties can avoid potential challenges to the enforceability of the award on grounds of lack of jurisdiction.
Another important consideration is the appointment of arbitrators. The arbitration clause should provide for the method of appointing arbitrators, whether by agreement of the parties or through the designated arbitration institution. It is advisable to include provisions for the qualifications and impartiality of arbitrators to ensure a fair and impartial arbitration process.
The arbitration clause should also address the governing law of the arbitration. In the UAE, parties are generally free to choose the governing law of the arbitration, provided that it is not contrary to public policy. However, it is recommended to choose a law that is familiar to the parties and that provides a clear framework for the enforcement of arbitration awards.
Furthermore, the arbitration clause should specify the seat of arbitration, which determines the jurisdiction in which the arbitration will take place. The seat of arbitration has implications for the enforcement of the award, as it is typically the courts of the seat that have jurisdiction to enforce the award.
Finally, the arbitration clause should include provisions for the confidentiality of the arbitration proceedings and the award. This is particularly important in the construction industry, where parties may wish to protect sensitive information from public disclosure.
By carefully drafting arbitration clauses that incorporate these best practices, parties can enhance the enforceability of arbitration awards in the UAE. This provides a solid foundation for resolving disputes efficiently and effectively, while ensuring that the outcome is legally binding and enforceable.
The Future of Arbitration Enforcement in the UAE
**Enforcement of Arbitration Awards in the UAE: A Comprehensive Overview**
The United Arab Emirates (UAE) has emerged as a prominent hub for international arbitration, owing to its robust legal framework and commitment to enforcing arbitration awards. The UAE’s construction law, in particular, provides a comprehensive framework for the enforcement of arbitration awards in the construction sector.
The UAE Arbitration Law (Federal Law No. 6 of 2018) governs the enforcement of arbitration awards in the UAE. Article 53 of the law states that an arbitration award issued in the UAE or abroad shall be enforceable if it meets certain conditions, including:
* The award must be final and binding.
* The award must not have been set aside or annulled by a competent court.
* The award must not be contrary to public policy or morality.
To enforce an arbitration award in the UAE, the party seeking enforcement must file an application with the competent court. The court will then review the award to ensure that it meets the aforementioned conditions. If the court is satisfied that the award is enforceable, it will issue an enforcement order.
The enforcement order can be executed by the court bailiff or any other person authorized by the court. The enforcement process may involve the seizure and sale of assets, the garnishment of wages, or other measures as deemed appropriate by the court.
The UAE has also acceded to the New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards, which provides for the reciprocal enforcement of arbitration awards between contracting states. This means that an arbitration award issued in a foreign country that is a party to the New York Convention can be enforced in the UAE, subject to certain conditions.
In addition to the legal framework, the UAE has established specialized courts and tribunals to handle arbitration matters. These courts have the expertise and experience to efficiently resolve disputes and enforce arbitration awards.
The UAE’s commitment to enforcing arbitration awards has made it an attractive destination for international arbitration. Parties involved in construction disputes can be confident that their arbitration awards will be recognized and enforced in the UAE, providing them with a reliable and effective means of dispute resolution.
As the UAE continues to develop its arbitration landscape, it is expected that the enforcement of arbitration awards will become even more streamlined and efficient. This will further enhance the UAE’s reputation as a leading center for international arbitration and dispute resolution.
Q&A
**Questions and Answers about Enforcement of Arbitration Awards in the UAE**
1. **Q: What is the legal basis for enforcing arbitration awards in the UAE?**
A: Federal Law No. 6 of 2018 on Arbitration
2. **Q: Which court has jurisdiction to enforce arbitration awards in the UAE?**
A: The Court of First Instance in the emirate where the arbitration award was issued
3. **Q: What are the requirements for enforcing an arbitration award in the UAE?**
A: The award must be final and binding, and it must have been issued by an arbitral tribunal seated in the UAE or recognized by the UAE
4. **Q: What is the procedure for enforcing an arbitration award in the UAE?**
A: The party seeking enforcement must file a petition with the court, along with a certified copy of the award
5. **Q: Can the court refuse to enforce an arbitration award?**
A: Yes, if the court finds that the award is contrary to public policy or morality, or if it was obtained through fraud or corruption
6. **Q: What is the time limit for enforcing an arbitration award in the UAE?**
A: Three years from the date the award becomes final and binding
7. **Q: Can an arbitration award be enforced against a non-UAE party?**
A: Yes, if the non-UAE party has assets in the UAE
8. **Q: What are the consequences of failing to comply with an arbitration award in the UAE?**
A: The court may impose fines or imprisonment on the party that fails to comply
9. **Q: Can an arbitration award be challenged in the UAE?**
A: Yes, through a limited number of grounds, such as fraud or corruption
10. **Q: What is the role of the Dubai International Arbitration Centre (DIAC) in enforcing arbitration awards?**
A: DIAC provides administrative support for the enforcement of arbitration awards issued under its rules
Conclusion
**Conclusion**
The enforcement of arbitration awards in the UAE is governed by Federal Law No. 6 of 2018 on Arbitration. This law provides a clear and efficient framework for the enforcement of arbitration awards, both domestic and international.
The UAE courts have a positive attitude towards the enforcement of arbitration awards. They recognize the importance of arbitration as a means of resolving disputes and are committed to upholding the sanctity of arbitration agreements.
The UAE is a party to the New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards. This means that arbitration awards made in other countries that are party to the Convention can be enforced in the UAE.
The UAE has also entered into bilateral agreements with a number of countries on the enforcement of arbitration awards. These agreements provide for the reciprocal enforcement of arbitration awards between the UAE and the other countries.
As a result of the UAE’s favorable legal framework and its commitment to the enforcement of arbitration awards, the UAE is a popular venue for international arbitration.
