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Article Disclaimer of Public Order as Grounds for Refusal to Recognize and Enforce a Foreign Arbitral Desicion of a Public Order Clause: Approaches of International Unified Documents
Authors Tepliuk S.
Name of magazine Legal journal «Law of Ukraine» (Ukrainian version)
Issue 9 / 2017
Pages 238 - 244
Annotation

The Paper analyses the types of wording of public policy exception as a ground for refusal of recognition and enforcement of foreign arbitral award. It has been concluded that the majority of international uniform instruments refer to «public policy of the state, where recognition and enforcement is sought». Inter-American Convention on Extraterritorial Validity of Foreign Judgements and Arbitral Awards explains the content of public policy exception to some extent.

Keywords public policy exception, New York Convention, Inter-American Convention, Riyadh Agreement, UNCITRAL Model Law on International Commercial Arbitration
References
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