On August 4, 2015, the D.C. Circuit issued a decision in Chevron Corp. v. Republic of Ecuador, 795 F.3d 200 (D.C. Cir. 2015), affirming the district court’s deference to the arbitrators’ decision on arbitrability for purposes of finding subject matter jurisdiction under the Foreign Sovereign Immunities Act (“FSIA”) to confirm an international arbitral award against Ecuador. The D.C. Circuit also upheld the district court’s rejection of a challenge to the award’s confirmation under the Convention on the Recognition…