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In a recent decision (“Decision”), the United States Court of Appeals for the Fifth Circuit the (“Appellate Court”) reversed the United States District Court for the Eastern District of Louisiana (the “District Court”) 2023 decision in Baker Hughes Saudi Arabia Co. Ltd. v. Dynamic Industries Saudi Arabia, Ltd. USDC No. 2:23-CV-1396 (“Baker Hughs Ruling”), remanding the case for further consideration. The Decision is important in the context of the effects of the Dubai Decree No.…

A. LEGISLATION AND RULES A.1 Legislation Arbitration proceedings in Türkiye are governed by the International Arbitration Act 2001[1] (IAL)[2] for cross-border disputes and by the Code of Civil Procedure of 2011 (CCP)[3] for domestic disputes without a foreign element. Both legal frameworks, which are modeled on the UNCITRAL Model Law, are recognized for their inclusiveness and for facilitating the arbitral process. The Law on International Private Law and Procedural Law (IPPL)[4] in Türkiye, adopted in…

Factual Background In “Milantic Trans SA (“Plaintiff”) v. Ministry of Production (Río Santiago Shipyard et al.) (“Respondent”) the Plaintiff requested the recognition and enforcement of two awards rendered by an arbitral tribunal seated in London, England (“Arbitral Tribunal”). The award on the merits was issued on November 15, 2004. The award on court costs and attorneys’ fees was issued on July 1, 2005. Decision of the Court of First Instance On November 17, 2006, the…

All well that ends well? After more than four years since the Brexit vote and just one week before the end of the Withdrawal Agreement between the United Kingdom and the European Union, both parties have reached a last-minute agreement on the future of trade and cooperation between them: the EU-UK Trade and Cooperation Agreement. This Agreement provisionally enters into force on 1 January 2021 and sets the ground rules for the new partnership between…