The American Society of International Law published, in the International Legal Materials (ILM), Volume 60, Issue 2, Marie-Laure Bizeau’s Introductory Note to Sofregaz v. NGSC. The ILM publishes significant international documents, e.g., treaties, UN Security Council resolutions, judgments, etc. with introductory notes from experts in the field.
In this article, Marie-Laure Bizeau talks about a landmark decision dated 3 June 2020 in which the International Commercial Chamber of the Paris Court of Appeal dismissed the annulment application brought by the Société Française d’Etudes et de Réalisation d’Equipements Gaziers (Sofregaz, now called TCM FR) of an arbitral award rendered in Paris on December 27, 2018, in favor of the Iranian Natural Gas Storage Company (NGSC), pursuant to the Rules of Arbitration of the International Court of Arbitration of the International Chamber of Commerce (ICC Rules). The Court ruled in particular that U.S. sanctions against Iran do not form part of French international public order but that European Union and United Nations sanctions do. This ruling provides, for the first time in the context of annulment proceedings, useful guidance on the interaction between international sanctions and international arbitration.
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