Domestic Law and International Conventions, the Imperfect Overlay: the FAA as a Case Study

This Article addresses several of the more important differences between the domestic portion of the Federal Arbitration Act and the Convention on the Recognition and Enforcement of Foreign Arbitral Awards. Specifically, practical tips for the commercial practitioner are set forth in connection with subject matter jurisdiction, statute of limitations applicable to enforcement of arbitration awards, venue considerations, and standards for vacatur of awards. The Domestic Legislation and the Convention are compared and contrasted with respect to the manner in which they each address these issues.