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.
To read the full version of the article, follow this link:
https://bit.ly/3cCY79d.