Comparative analysis of arbitration rules

Below is a brief summary of the arbitration provisions in the LCIA Rules, UNCITRAL Rules, and ICSID Rules which have been considered in particular in relation to the Investment Agreement.

From the preferred perspective, it is recommended that any arbitration against host country under the Investment Agreement preferably be commenced under the ICSID Rules because ICSID awards are easier to enforce and leave no ground for national authorities to hold that the award is invalid. In the project agreements, the LCIA is considered to be a good option and likewise recommend keeping the reference to the LCIA in the Investment Agreement if this can be agreed to. However, the host country Government has requested th...

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Comparative analysis of arbitration rules

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