Chromalloy: United States law and international arbitration at the crossroads

Article Abstract:

The US DC District Court 1996 decision in Matter of Chromalloy Aeroservices (Arab Republic) demonstrates the difficulties US courts have in responding to issues initiated in foreign courts. An Egyptian Court of Appeals nullified an award mandated by an arbitration panel, and the DC District Court upheld the award. The District Court incorrectly applied Article VII of the Convention on the Recognition and Enforcement of Foreign Arbitral Awards. Article V of the Convention provides a better foundation for a court's interpretive decision. The Convention provides guidelines for domestic courts interpreting foreign arbitration decisions

Conflict of laws, Jurisdiction, Commercial arbitration

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Achieving restitution: the potential unjust enrichment claims of indigenous peoples against multinational corporations

Article Abstract:

The author argues that the legal remedy of unjust enrichment can provide the world's indigenous peoples with a valuable tool to make up for losses resulting from the exploitation of their lands by foreign multinational corporations. Relevant US courts cases are examined.

International business enterprises, Multinational corporations, Indigenous peoples, Unjust enrichment

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