Enforcement of International Arbitration Awards. A Comparative Study between Egypt, USA, and the Gulf Cooperation Council Countries

      Аннотация: International commercial arbitration has become the most popular mean for settlement of international commercial transactions, however, the effectiveness and success of any arbitration process depends on the ability to enforce the award rendered. This work examines the enforcement mechanism of international arbitration awards in different jurisdictions such as the United States of America, Egypt and the Gulf Cooperation Council (GCC) countries (Saudi Arabia, Qatar, Bahrain, Kuwait, United Arab Emirates and Oman). Although these countries are members to the New York Convention, however, their domestic laws play an important role in the process of enforcement. Also, this research explores the recent development in arbitration laws and enforcement mechanism and how these countries enforce international arbitration awards in the light of the provisions of Islamic Shari'a.

Ключевые слова: USA, Egypt, International Commercial Arbitration, New York Convention, Enforcement, Arbitral Awards, GCC, setting aside, Pubic Policy