Duty and discretion in international arbitration

International arbitration implicates complex relationships between the place of arbitration and the location of the party's assets, which have been highlighted by cases recognizing foreign awards despite their vacatur at the arbitral situs. The author examines the extent to which enforcement of vacated awards comports with the parties' expectations and arbitration's treaty framework. The author suggests that the United States enact a statute clarifying the role and scope of federal judicial supervision of international commercial arbitration.