The Panama Convention & Its Implemetation Under the Federal Arbitration Act

This book provides the first comprehensive analysis of the Panama Convention, its implementation legislation in the United States, and United States court decisions construing its provisions. By comparing the Panama and New York Conventions, it identifies important differences, such as the Panama Convention's mandatory application of the Rules of Procedure of the IACAC to ad hoc arbitrations and differences in the Conventions' provisions concerning the grounds for recognition and enforcement of arbitral awards. By comparing Chapter 3 of the Federal Arbitration Act with the other provisions of the federal act, this book exposes problems in the implementing law as well as ways in which Chapter 3 improves on the federal law implementing the New York Convention. Through a critical review of Convention jurisprudence in the United States, it highlights at last three areas in which the courts need to do a much better job: the Convention's field of application, application of the IACAC Rules, and differentiation between the New York and Panama Conventions.