Duty and Discretion in International Arbitration

International arbitration implicates complex relationships between the law of the place of arbitration and the law of the country where the parties\u27 assets are located. The interaction of these legal orders has been highlighted by cases recognizing foreign awards notwithstanding their vacatur at the arbitral situs. The author examines the extent to which enforcement of vacated awards comports with the parties\u27 expectations and arbitration\u27s treaty framework. This Article suggests that the United States enact a statute clarifying the role and scope of federal judicial supervision of international commercial arbitration