Emmanuel Gaillard

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Partner
In memoriam

Professor Gaillard was the founding partner of Gaillard Banifatemi Shelbaya Disputes and was universally regarded as one of the top practitioners worldwide and as a leading global authority in the fields of commercial and investment treaty arbitration. Through his work as counsel and his scholarly writings, he helped shape the theory and practice of international arbitration as it is known today. Prior to founding Gaillard Banifatemi Shelbaya Disputes, Professor Gaillard had founded Shearman & Sterling’s International Arbitration practice, which he led for over thirty years and grew into one of the world’s premier practices.

He acted as lead counsel in hundreds of international arbitrations and regularly acted as arbitrator and expert witness. Professor Gaillard secured many landmark victories for his clients, including a USD 50 billion award for the majority shareholders of the former Yukos Oil Company, the largest investment award in history, and a USD 2.47 billion award in favor of Dow Chemical, the then largest commercial award ever rendered.

Professor Gaillard was one of only two lawyers recognized as a ‘star individual’ in international arbitration worldwide by Chambers and Partners. Professional directories and publications have noted Professor Gaillard’s “incredible wealth of knowledge and experience” and “fantastic record in the field” and praised him for “his understanding of multiple perspectives to a case”. Who’s Who legal added “there is no one in this profession better or even equally formidable”.

A Professor of Law in France, Professor Gaillard was also a Visiting Professor of Law at Yale Law School and Harvard Law School. He wrote extensively on all aspects of arbitration law, in French and in English and he was distinguished as the number one thought leader globally in Who’s Who Legal: Arbitration 2020. He co-authored a leading treatise in the field (Fouchard Gaillard Goldman On International Commercial Arbitration) and he authored the first published essay on the legal theory of international arbitration. The volume, originally published in French (Aspects Philosophiques du droit de l’arbitrage international), was subsequently published in English (Legal Theory of International Arbitration), as well as in Arabic, Chinese, Spanish and a number of other languages. He co-authored, as expert acting for UNCITRAL, the UNCITRAL Secretariat Guide on the New York Convention, published in the six official languages of the United Nations.

Professor Gaillard also served as member of the ICSID Panel of Arbitrators, appointed by France (2006–2018). He chaired the International Arbitration Institute (IAI) and was the first President and one of the co-founders of the International Academy for Arbitration Law (AIDA or Arbitration Academy).

AS COUNSEL

Investment treaty arbitration

The People’s Republic of China in an ICSID arbitration brought by Hela Schwarz GmbH (ICSID Case No. ARB/17/19). The claims were brought under the China-Germany bilateral investment treaty.
The Republic of Lithuania, Respondent in an ICSID arbitration brought by Veolia Environnement S.A. and others in relation to district heating and power generation systems in Lithuania (ICSID Case No. ARB/16/3). The claims are brought under the Lithuania-France bilateral investment treaty. The dispute revolves around, inter alia, allegations of corruption, collusion, self-dealing, anti-competitive conduct and tariff manipulation.
Georgia, Respondent in an SCC arbitration initiated by Mr. Zaza Okuashvili under the Georgia-U.K. bilateral investment treaty. The dispute relates to taxes owed to the State by various companies owned by the Claimant.
Ukraine, Respondent in a UNCITRAL arbitration brought by PJSC Gazprom. The dispute concerned the enforcement of a fine issued by the Anti-Monopoly Committee of Ukraine in relation to Gazprom’s breaches of Ukraine’s competition law in the performance of a gas transit contract. The claims were brought under the Ukraine-Russia bilateral investment treaty.
The People’s Democratic Republic of Algeria in an ICSID arbitration initiated by Orascom TMT Investments S.à.r.l. (ICSID Case No. ARB/12/35). The dispute related to alleged breaches of the Algeria-Belgium-Luxembourg Economic Union bilateral investment treaty in relation to the operation of a mobile telephone company in Algeria. The USD 4 billion claim brought against our client was dismissed in its entirety.
The majority shareholders of the former Yukos Oil Company, Claimants in three UNCITRAL arbitrations in The Hague against the Russian Federation in relation to the expropriation of their investment in the company. The claims were brought under the Energy Charter Treaty. Following two awards, one of 2009 on jurisdiction and admissibility and one of 2014 on merits, the Tribunal held the Russian Federation liable for breaches of international law and ordered it to pay over USD 50 billion in damages to our clients, the largest award ever rendered by an arbitral tribunal. The Tribunal also ordered the Respondent to reimburse to our clients 75% of the legal fees incurred in these proceedings, as well as 100% of the arbitration costs. Following the issuance of the award on the merits in 2014, Professor Gaillard has continued his representation of the Yukos majority shareholders, in relation to both setting aside proceedings initiated in The Hague by the Russian Federation and having resulted in The Hague Court of Appeals upholding the award in the Netherlands, as well as enforcement proceedings in multiple jurisdictions.

Energy

Sonangol in three parallel NAI arbitrations in Amsterdam against a European holding company beneficially owned by Isabel dos Santos. The dispute relates to high-profile allegations of embezzlement, corruption and money-laundering in relation to a joint venture agreement. Dutch and Angolan law applies. To date, Sonangol has enjoyed a complete victory in one of the three arbitrations and the Enterprise Chamber of the Amsterdam Court of Appeal has frozen the assets of the relevant offshore holding company.
Two Egyptian State-owned entities in a USD 6 billion ICC arbitration in Geneva and a USD 4 billion CRCICA arbitration in Cairo arising out of a long-term gas supply contract relating to the export of Egyptian gas to Israel. English law applied to both arbitrations. More than three quarters of the Claimants’ claims were dismissed for lack of jurisdiction or on the merits. We also represented the Arab Republic of Egypt, Respondent in two investment arbitrations concerning alleged violations under the Egypt-Poland, Egypt-U.S. and the Egypt-Germany bilateral investment treaties relating to the performance of the same long-term contract for the supply of natural gas. Around USD 2 billion were claimed in the investment disputes. More than two thirds of the Claimants’ claims were dismissed on jurisdictional grounds and on the merits. Following these decisions, the parties reached a global settlement, under which all claims against our clients were waived without our clients being required to make any payment.
A West African State-owned energy company in an ICC arbitration in London initiated by a local subsidiary of a North American oil company. The dispute arose from a purchase and sale agreement related to concession rights in two deepwater oil blocks off the coast of the African State. Over USD 2.2 billion was at stake.
A Middle Eastern State-owned gas company, Respondent in two CRCICA arbitrations brought by a European energy company. The dispute arose from a gas supply agreement. Egyptian law applied.
Nine Asian Independent Power Producers (IPPs) in an LCIA arbitration in London brought against a Pakistani State-owned entity. The dispute arose out of the non-payment of certain amounts under Power Purchase Agreements concluded between the IPPs and the State-owned entity. Pakistani law applied. The USD 100 million claim brought against our client was dismissed in its entirety.
A European energy company, seller in a long-term gas supply agreement, Respondent in a gas price review arbitration brought by another European energy company (as buyer). Over USD 1.3 billion was at stake. Algerian law applied. A settlement was achieved by the parties.

M&A and Joint Ventures

A European pharmaceutical company, Respondent in an ICC arbitration in Geneva initiated by a European life sciences company. The dispute arises out of an acquisition and the settlement of third party claims. Swiss law applies.
A Middle Eastern businessman in an ICC arbitration in Geneva related to the dissolution of a long-standing family partnership. The law of a Gulf State applies. Billions of dollars are at stake.
A group of shareholders of a holding company, Claimants in an ICC arbitration in Paris against two shareholders in the same company. The dispute concerned the interpretation of a put option price provision contained in a Shareholders’ Agreement. The law of the Netherlands applied. Over USD 1 billion was at stake.
The Dow Chemical Company in an ICC arbitration in London against Petrochemical Industries Company (PIC) arising out of the failure of the latter to close a large joint venture transaction. English law applied. Dow was awarded more than USD 2.47 billion.
EDF International in an ICC arbitration in Zurich initiated by a company fully-owned by the German Land of Baden-Württemberg. The dispute arose from the acquisition by the Land of EDF’s stake in an energy company based in the Land and raised complex issues of EU law. German law applied. The EUR 4.6 billion claim brought against our client was dismissed in its entirety.

Other matters

Sportfive EMEA (formerly Lagardère Sports), Claimant in an ICC arbitration in Geneva against the Confederation of African Football (CAF). The dispute arises from the termination by CAF of a USD 1 billion exclusive television and marketing rights agreement. Swiss law applies.
A French-German consortium in an ICC arbitration in Stockholm against a Finnish utility company. The dispute arose from an agreement for the construction of a nuclear power plant in Finland. Finnish law governed. Over EUR 6.1 billion was at stake.
An international logistics company and port operator in two ad hoc arbitrations arising from the breach of a concession agreement and a framework agreement. The first arbitration was brought against the port authority of an African State. The second arbitration was brought against the same port authority and the State.
An international joint venture in an ICC arbitration in Geneva brought against North Asian contractors. The dispute arose from an agreement for the construction of a fertilizer plant in an African State. The law of the African State applied.
Numerous post-award proceedings to seek the setting aside or the enforcement of awards rendered in commercial and investment treaty arbitrations.

AS ARBITRATOR

Professor Gaillard has served as Chairman, Sole arbitrator or member of the tribunal in numerous international arbitration proceedings under the Arbitration Rules of ICSID, ICC, LCIA, SIAC, IACAC, AAA, Franco-German Chamber of Commerce, Zagreb Chamber of Commerce, Geneva Chamber of Commerce and Industry, Cairo Regional Center for International Commercial Arbitration (CRCICA), as well as in ad hoc (including UNCITRAL) arbitration proceedings. He was a member of the ICSID Panel of Arbitrators, designated by France (2006–2018).

Investment arbitrations in the public domain include:

Federal Elektrik Yatırım ve Ticaret A.Ş. and others v. Republic of Uzbekistan (Arbitrator, appointed by the Claimant, ICSID Case No. ARB/13/9). Dispute relating to the renovation and development of a natural gas system. Claims brought under the 1992 Turkey-Uzbekistan bilateral investment treaty, the Energy Charter Treaty and the 1998 Uzbekistan investment statute.
EuroGas Inc. and Belmont Resources Inc. v. Slovak Republic (Arbitrator, appointed by the Claimant, ICSID Case No. ARB/14/14). Dispute relating to a talc mining enterprise. Claims brought under the 1991 U.S.-Slovak Republic and the 2010 Canada-Slovak Republic bilateral investment treaties.
CEZ AS v. Albania (Arbitrator, appointed by the Republic of Albania, UNCITRAL Case). Dispute relating to a power distribution enterprise. Claims brought under the Energy Charter Treaty.
MNSS B.V. and Recupero Credito Acciaio N.V. v. Montenegro (Arbitrator, appointed by the Claimant, ICSID Case No. ARB (AF)/12/8). Dispute relating to steel production. Claims brought under the 2002 Netherlands-Yugoslavia bilateral investment treaty and the 2011 Montenegro investment statute.
Lundin Tunisia B.V. v. Republic of Tunisia (Arbitrator, appointed by the Claimant, ICSID Case No. ARB/12/30). Dispute relating to oil exploration and exploitation operations. Claims brought under a contract.
Toto Costruzioni Generali S.p.A. v. Republic of Lebanon (President of the Ad hoc Committee, ICSID Case No. ARB/07/12). Dispute relating to a highway construction. Claims brought under the 1997 Lebanon-Italy bilateral investment treaty.
Commerce Group Corp San Sebastian Gold Mines, Inc. v. Republic of El Salvador (President of the Ad hoc Committee, ICSID Case No. ARB/09/17). Dispute relating to a mining concession. Claims brought under the Dominican Republic-Central America Free Trade Agreement (CAFTA-DR) and the 1999 El Salvador investment statute.
Global Trading Resource Corp. and Globex International, Inc. v. Ukraine (Arbitrator, appointed by the Claimants, ICSID Case No. ARB/09/11). First award rendered under ICSID Arbitration Rules 41(5), a provision allowing for summary dismissal of claims which are “manifestly without merit.” Claims brought under the 1994 U.S.-Ukraine bilateral investment treaty.
Saba Fakes v. Republic of Turkey (President, appointed by the parties, ICSID Case No. ARB/07/20). Dispute relating to mobile telecommunications services. Claims brought under the 1986 Netherlands-Turkey bilateral investment treaty.
Shareholders of SESAM v. Central African Republic (President, appointed by the parties, ICSID Case No. CONC/07/1). Conciliation concerning a log production and processing enterprise. Claims brought under a contract.
Victor Pey Casado and President Allende Foundation v. Republic of Chile (Arbitrator, appointed by ICSID, ICSID Case No. ARB/98/2). Dispute arising out of the alleged expropriation of a newspaper company by Chile’s military junta. Claims brought under the 1991 Chile-Spain bilateral investment treaty.
Cargill, Incorporated v. Republic of Poland (Arbitrator, appointed by the Claimant, former ICSID Case No. ARB(AF)/04/2). Claims brought under the 1990 U.S.-Poland bilateral investment treaty.
Canfor Corporation v. USA (President, appointed by agreement between the parties, arbitration under the UNCITRAL Arbitration Rules and NAFTA). Arbitration regarding the effect of U.S. antidumping and countervailing duty determinations (including the Byrd Amendment of 2000) on the softwood lumber industry made by the U.S. Department of Commerce. Case consolidated with two other arbitrations relating to softwood lumber before the same Consolidated Tribunal under NAFTA Article 1126.
Consortium Groupement L.E.S.I.-DIPENTA v. Algeria (Arbitrator, appointed by the Republic of Algeria, ICSID Case No. ARB/03/8). Dispute arising out of the construction of a dam by Italian companies in Algeria. Claims brought under the 1991 Italy–Algeria bilateral investment treaty.
E.S.I. SpA and Astaldi SpA v. Algeria (Arbitrator, appointed by the Republic of Algeria, ICSID Case No. ARB/05/3). Dispute arising out of the construction of a dam by Italian companies in Algeria. Claims brought under the 1991 Italy–Algeria bilateral investment treaty.
PT Aria West International v. PT Telekomunikasi Indonesia Tbk (Arbitrator, appointed by the Claimant, ICC arbitration, Geneva). Dispute arising out of a joint operating agreement between a foreign investor and Indonesia’s State phone company for building and operating a fixed-lined phone service in West Java.

AS EXPERT

Emmanuel Gaillard regularly appeared as expert in international arbitration proceedings as well as in court proceedings, in particular with respect to the recognition and enforcement of arbitral awards in a number of countries.

Mandates as expert include:

ICSID arbitration regarding the alleged breach of an African State’s investment code.
Expert report on French international arbitration law before the High Court of England and Wales in connection with a request for enforcement of an award.
ICC arbitration between Andersen Consulting and Arthur Andersen.
LCIA arbitration between True North Communications and Publicis.
ICC arbitration between AT&T Corp. and Saudi Cable Company.
Action brought before the U.S. District Court for the District of Columbia by International Bechtel Company against Dubai regarding the enforcement of an award set aside in the country of origin.
Action brought before the U.S. District Court for the Southern District of Florida by Four Seasons Hotels against Consorcio Barr for the enforcement of a AAA award rendered in Miami and set aside in Venezuela.
Action brought before the Superior Court of Quebec by Tusculum B.V. against Louis Dreyfus & Cie to vacate an order and final award by an ICC arbitral tribunal on the ground that it decided issues allegedly decided in an earlier partial award.

Emmanuel Gaillard offers states and private entities outstanding expertise in an array of international arbitration and PIL matters. He is widely regarded as one of the foremost figures in investor-state disputes, and also excels in commercial arbitration. One source reports: ‘He is in a league of his own, he is absolutely outstanding.’ – Chambers Global 2020 – International Arbitration (Global-wide) and Chambers Global 2020 – Public International Law (Global-wide)
Emmanuel Gaillard is regarded as a standout name in the arbitration space, acting as both counsel and arbitrator. He comes recommended for his handling of complex commercial and investor-state arbitration cases across various jurisdictions in Europe, as well as in Africa and Latin America. A source deems him to be ‘at the forefront of the profession,’ with ‘impressive rhetorical verve.’ – Chambers Global 2020 – International Arbitration (Europe-wide)
Emmanuel Gaillard is a highly distinguished disputes lawyer who is widely considered to be a market leader in international arbitration. His formidable set of skills range from his strengths in oral advocacy to the depth of his strategic advice. He is best known for representing states and state-owned entities in disputes relating to the energy, oil and gas, petrochemical and construction industries. Frequently cited as ‘a superstar in the international arbitration world,’ one client lauded him by saying: ‘He’s perfect! He’s one of the best legal representations that we can get and it’s a pleasure to work with him.’ – Chambers Global 2020 – Dispute Resolution: (Africa-wide)
Emmanuel Gaillard is described as ‘the most important practitioner in the Paris arbitration market.’ His wide-ranging practice sees him acting as counsel and arbitrator on high-stakes commercial and investment treaty arbitrations. He is described by one interviewee as an ‘outstanding litigator,’ while another praises him for being ‘very modest, charismatic and creative.’ – Chambers Global 2020 – Dispute Resolution: International Arbitration (France)
Emmanuel Gaillard . . . is a household name in the field of international arbitration, possessing outstanding expertise in Europe and North Africa. He . . . posseses vast experience in the energy sector. – Chambers Global 2020 – International Arbitration and Most In Demand Arbitrators (Global-wide)
Emmanuel Gaillard is a world-renowned arbitration expert . . . He is recognised for his expertise in handling arbitration related to state-owned entities, as well as acting for clients in disputes related to bilateral investment treaties. – Chambers Global 2020 – Corporate/Commercial – Foreign expert based in France (Algeria)
Paris-based Emmanuel Gaillard is a towering international arbitration specialist who provides considerable insight and expertise for high-profile, multi-jurisdictional arbitrations involving key Russian players. Corporate conflicts, energy supply disputes and financial disputes are all areas of particular experience. – Chambers Global 2020 – Corporate/Commercial – Foreign expert based in France (Russia)
Emmanuel Gaillard is one of the world’s foremost arbitration specialists. Peers describe him as ‘the name in arbitration in France’ and ‘a very sharp practitioner’. – Who’s Who Legal: Arbitration – Global Elite Thought Leader 2020
Emmanuel Gaillard ‘is a clear leader in his field’ of commercial and investment treaty arbitration and is widely endorsed as ‘a major and deeply influential player.’ – Who’s Who Legal: Arbitration 2019
Based in Paris, Emmanuel Gaillard is universally recognised as ‘one of the top figures in international arbitration worldwide.’ He attracts high praise for his adept handling of commercial and investor-state proceedings and is a popular choice of counsel among corporates and sovereign states alike. One impressed interviewee said: ‘He is great both practically and academically,’ whilst another concludes: ‘He certainly is a star.’ – Chambers Global 2019 – International Arbitration (Global-wide)
The ‘formidable’ Emmanuel Gaillard is a top player in international disputes and is deemed by market observers to be a ‘first-rate intellect’ who is ‘full of ideas, perspicacity and authority.’ He regularly represents corporations and respondent states in high-stakes BIT disputes arising in the telecoms, mining, energy and construction sectors. He is based in Paris. – Chambers Global 2019 – Public International Law (Global-wide)
Peers describe Paris-based Emmanuel Gaillard as ‘really exceptional’ and ‘very versatile.’ Also deemed to be ‘outstanding,’ he boasts a leading global reputation and is highly sought after as an advocate in complex cases, as well as frequently sitting as arbitrator. Gaillard represents a range of private companies, state-owned entities and governments in major international proceedings. Sources note that he is ‘intellectually very powerful, can plead difficult cases convincingly and is realistic and down-to-earth.’ – Chambers Global 2019 – International Arbitration (Europe-wide)
‘Global star’ Emmanuel Gaillard is admired by market commentators, who call him a ‘top name in the profession.’ Sources agree that ‘he’s a great guy and a powerful figure’ in this market. He possesses considerable experience in energy disputes and other significant arbitrations, with clients highlighting in particular his expertise across North Africa. He heads the global disputes practice as well as the firm’s international arbitration group from the firm’s Paris office. – Chambers Global 2019 – Dispute Resolution (Africa-wide)
Emmanuel Gaillard ‘understands the essence of a matter quickly and is able to explain it to us in very simple concepts and words.’ Gaillard is widely regarded as a leading figure in the Paris arbitration field owing to his vast experience as counsel and as arbitrator in important investment treaty and commercial arbitrations. ‘He is intellectually very strong and can plead difficult cases convincingly,’ reports another impressed interviewee. – Chambers Global 2019 – Dispute Resolution: International Arbitration (France)
Emmanuel Gaillard is widely praised for his significant contribution to the field of arbitration and is picked out as an extremely bright lawyer. He is applauded for his expertise in both commercial and investment treaty matters, advising sovereign states and commercial bodies alike. Based in Paris, he is particularly prominent in European and African disputes. – Chambers Global 2018 – International Arbitration (Global-wide)
Paris-based Emmanuel Gaillard is recognised in the market as a leading figure in the field and one of the very best in investment treaty arbitrations. A distinguished authority on ICSID arbitration, he has acted for both private sector claimants and sovereign states on a number of landmark cases. He also offers deep expertise in commercial arbitration. – Chambers Global 2018 – Public International Law (Global-wide)
Emmanuel Gaillard enjoys a tremendous reputation in the market as a leading arbitration expert. Peers note his superb advocacy skills and ability to quickly summarise the issues in an effective manner, while clients highlight his strategic view of cases as a key advantage. Paris-based Gaillard leads many of the firm’s most important cases, having played a key role in advice to GML on its long-running dispute with the Russian Federation following the latter’s expropriation of shares in Yukos Oil Company. He also earns praise as a popular arbitrator in ICSID and ICC cases. – Chambers Global 2018 – International Arbitration and Most In Demand Arbitrators (Europe-wide)
Emmanuel Gaillard is lauded as an outstanding personality in the arbitration community and is praised for his understanding of multiple perspectives to a case. He is particularly skilled at advising state-owned entities in various areas, including investment and disputes flowing from the energy sector. Clients also add that his strategic view of cases produces high-value advice. – Chambers Global 2018 – Dispute Resolution: International Arbitration and Most In Demand Arbitrators (France)
. . . Emmanuel Gaillard is widely respected for his work on significant arbitrations across francophone North Africa, with impressive experience in the energy sector. Market commentators recognise the impressive status Gaillard s name carries within the market and add that there is no doubt as to his quality. – Chambers Global 2018 – Dispute Resolution: (Africa-wide)
Paris-based Emmanuel Gaillard . . . is universally recognised as one of the stars of international arbitration. His Russian experience relates to extremely high-value international arbitration disputes, including the USD50 billion Yukos shareholders case against the Russian Federation. – Chambers Global 2018 –Dispute Resolution, Foreign expert based in France (Russia)
Emmanuel Gaillard . . . is highly respected as an ‘arbitration specialist’ in the local and international arenas. Sources praise him as ‘very active in Algeria’ and go on to laud his significant experience. He is based in Paris. – Chambers Global 2018 – Corporate/Commercial – Foreign expert based in France (Algeria)
Emmanuel Gaillard is ‘absolutely outstanding’, according to respondents, who highlight his ‘excellent reputation as counsel’ as well as his position as ‘a real star in the field’. – Who’s Who Legal: Arbitration 2018
Emmanuel Gaillard is ‘an exceptionally smart lawyer’ who is highlighted for ‘the impressive quality of his work’ on large international disputes. Sources consider him ‘an outstanding figure’ in the French market who ‘always delivers the goods’. – Who’s Who Legal: France 2018

Visiting Professor of Law, Yale Law School (2014–) and Harvard Law School (1984, 2018–)
Professor of Law, École de Droit, Sciences Po (2012–14)
Visiting Professor of Law, University of Geneva (2009–)
President and co-founder, International Academy for Arbitration Law (2011–13)
Member, appointed by France, ICSID Panel of Arbitrators (2006–18)
President, International Arbitration Institute (IAI)
Member, Supreme Court of the People’s Republic of China’s International Experts Committee (2018–2021). The Committee’s role includes “providing advice and suggestions on the formulation of judicial interpretations and judicial policies of the Supreme People’s Court”.
Member, Editorial Advisory Board, ICSID Review – Foreign Investment Law Journal
Director, Journal du droit international
Member, International Council for Commercial Arbitration (ICCA)
Chair, International Arbitration Committee, International Law Association (1989–96)
Member, Comité Français de l’Arbitrage (CFA), Comité Français de Droit International Privé, Swiss Arbitration Association (ASA)
Member, LCIA Court (2002–07)
Chair, Advisory Board of the Mauritius International Arbitration Center (MIAC) (2019–)
Council Member, Australian Centre for International Commercial Arbitration (ACICA) (2019–22)
Member, HKIAC International Advisory Board (2017–)
Advisory Board Member, Institute for Transnational Arbitration (ITA)
Member, Board of Trustees of the Foundation for International Arbitration Advocacy
Member, SIAC Court of Arbitration (2013–19)

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