The Formal Requirements for Enforcing an Arbitral Award under the 1958 New York Convention, Between Autonomous Interpretation and References to Domestic Legal Systems

1. The pursuit of an autonomous interpretation of international conventions, especially as concerns uniform law and private international law instruments, and its relevance in respect of the New York Convention. 2. Autonomous interpretation and references to domestic legal systems: problems arising in respect of lacunae in an international convention and different means of filling them in. 3. The insufficiency of a reference to the general principles inherent in the relevant convention in respect of technical or procedural issues, such as those raised by Article IV of the New York Convention. 4. The identification of suitable criteria for selecting the law in accordance to which such issues shall be solved, between the law at the seat of the arbitration and the law at the place of enforcement of the award. 5. Policy considerations supporting either solution and the interplay between autonomous interpretation of the New York Convention and autonomy of international commercial arbitration. 6. Concluding remarks.