International Arbitration Training Course

Participants can identify the legal sources governing an international arbitration.

• UNCITRAL Model Law structure and its adoption by national legislatures
• New York Convention obligations concerning recognition and enforcement
• Arbitration agreement law distinguished from substantive contract law
• Lex arbitri determines mandatory procedural safeguards and court supervision
• Conflict-of-laws analysis identifies governing law for disputed obligations
• Mandatory rules and public policy affecting contractual enforceability

Participants can draft clear arbitration clauses that reduce procedural uncertainty.

• Core arbitration clause elements: consent, seat, rules, language, tribunal
• Model clauses from ICC, LCIA, SIAC and UNCITRAL
• Multi-tier clauses combining negotiation, mediation and arbitration steps
• Drafting escalation provisions with defined timelines and authorised representatives
• Pathological clauses diagnosed through ambiguity, inconsistency and missing terms
• Joinder, consolidation and multi-contract provisions for complex transactions

Participants can build an early arbitration assessment to guide procedural and commercial decisions.

• Chronology construction from contract documents, correspondence and project records
• Issue trees separating liability, causation, quantum and procedural questions
• Merits assessment using legal elements, facts and available proof
• Limitation periods, notice requirements and contractual preconditions assessed early
• Counterparty asset mapping informs settlement and enforcement priorities
• Settlement ranges developed from probability-weighted damages scenarios

Participants can commence proceedings and respond to jurisdictional challenges.

• Request for arbitration requirements under major institutional rules
• Notice of arbitration drafted for ad hoc UNCITRAL proceedings
• Prima facie jurisdiction decisions by arbitral institutions and tribunals
• Kompetenz-kompetenz and separability applied to contested arbitration agreements
• Jurisdictional objections based on parties, scope, form and authority
• Anti-suit injunctions and parallel proceedings considered strategically

Participants can plan tribunal appointments and assess arbitrator suitability.

• Sole arbitrator and three-member tribunal appointment mechanisms
• Party nominations balanced against independence, availability and subject expertise
• IBA Guidelines on Conflicts of Interest categories
• Arbitrator disclosures reviewed for relationships, appointments and potential bias
• Challenge procedures, deadlines and appointing authority decisions
• Tribunal secretary roles, appointment safeguards and disclosure requirements

Participants can prepare a practical procedural plan for an arbitral proceeding.

• First case management conference agenda and procedural priorities
• Procedural Order No. 1 structure, content and drafting conventions
• Redfern Schedule used to organise document production requests
• Bifurcation assessed for jurisdiction, liability and quantum issues
• Procedural timetables built around pleadings, evidence and hearing dates
• Cybersecurity protocols for confidential filings and electronic hearing bundles

Participants can structure persuasive written submissions grounded in evidence and law.

• Case theory links contractual duties, facts, evidence and relief
• Statement of claim organised around pleaded causes of action
• Statement of defence addresses admissions, denials and affirmative defences
• Memorial drafting uses issue-led headings and proposition-based paragraphs
• Authorities cited with pinpoint references and procedural relevance
• Prayer for relief specifies damages, interest, costs and declarations

Participants can manage document production and factual evidence under international practice.

• IBA Rules Article 3 document request requirements
• Narrow categories defined through relevance, materiality and reasonable scope
• Objections framed around privilege, burden, confidentiality and possession
• Redfern Schedule responses prepared with precise production positions
• Document preservation notices issued before deletion or data loss
• Fact witness statements distinguish personal knowledge from argument

Participants can plan witness and expert evidence for a contested arbitration.

• Witness selection based on direct knowledge, credibility and availability
• Witness preparation distinguishes lawful familiarisation from improper coaching
• Expert evidence scoped through instructions, assumptions and methodology
• Party-appointed experts compared with tribunal-appointed expert procedures
• Legal professional privilege assessed across common-law and civil-law systems
• Expert conferencing and joint statements narrow technical disagreements

Participants can assess and seek urgent protective measures before or during arbitration.

• Interim measures protect assets, evidence, confidentiality and contractual performance
• Emergency arbitrator procedures under ICC and SIAC rules
• Urgency, necessity and irreparable harm tests for provisional relief
• Security for costs applications assessed against claimant solvency evidence
• Court assistance for evidence preservation and third-party orders
• Undertakings in damages and security requirements evaluated before applications

Participants can frame damages and costs submissions supported by an appropriate valuation approach.

• Expectation damages calculated from contractual performance and breach consequences
• Causation and remoteness tests applied to claimed commercial losses
• Discounted cash flow method assessed for lost-profit claims
• Mitigation evidence tested against reasonable alternative actions
• Pre-award and post-award interest calculated using stated rates
• Costs submissions address allocation, reasonableness and party conduct

Participants can prepare a disciplined hearing plan and present key submissions effectively.

• Hearing bundles indexed with agreed documents and disputed exhibits
• Opening statements present the case theory and hearing roadmap
• Cross-examination plans use propositions, documents and controlled questioning
• Re-examination addresses material damage without repeating direct evidence
• Tribunal questions handled through precise answers and record references
• Closing submissions connect findings sought to evidence and legal tests

Participants can review awards and identify available post-award procedural steps.

• Award requirements concerning reasons, signatures, date and place
• Majority decisions, dissents and tribunal deliberation confidentiality
• Interpretation and correction requests made within institutional deadlines
• Set-aside grounds under Model Law Article 34
• Due process objections assessed through notice, equality and opportunity
• Annulment risk analysed without reopening merits of the dispute

Participants can prepare an enforcement strategy for an international arbitral award.

• New York Convention Article V refusal grounds analysed
• Asset tracing identifies viable jurisdictions for enforcement proceedings
• Recognition procedures distinguished from execution against debtor assets
• Sovereign immunity issues considered in state and entity disputes
• Enforcement defences based on public policy and procedural irregularity
• Settlement enforcement planning begins before the final award

Participants can coordinate internal stakeholders, external counsel and decision-making throughout an arbitration.

• Internal legal holds preserve documents across business units
• Counsel instructions define objectives, authority limits and reporting cadence
• Privilege protocols protect communications with lawyers and technical experts
• Budget trackers separate tribunal, counsel, expert and hearing costs
• Board reporting presents exposure, milestones, settlement and enforcement options
• Lessons-learned reviews improve future contracting and dispute prevention

Participants can build, review and present a complete international arbitration case file with procedural, evidential and enforcement recommendations.

• Case chronology establishes disputed events, notices and contractual milestones
• Arbitration clause assessment identifies seat, rules and jurisdictional risks
• Claim and defence matrix links allegations to supporting evidence
• Procedural strategy sets tribunal, timetable, disclosure and hearing priorities
• Damages model states assumptions, valuation method and interest approach
• Enforcement memorandum identifies assets, Convention issues and recommended jurisdictions