OBSERVARE

Universidade Autónoma de Lisboa

e-ISSN: 1647-7251

VOL. 17, N.º 1

May 2026

658

NOTES AND RELECTIONS

SHAPING GLOBAL RELATIONS THROUGH INTERNATIONAL

ARBITRATION: RECENT TRENDS AND OPTIONS

MISHA BAHMANI

drmishabah@gmail.com

Assistant Professor in IILM University, Gurugram, India. She was awarded doctorate of

philosophy from Guru Gobind Singh Indraprastha University, Delhi (India). Her academic and

research interests lie in the domain of International Commercial Arbitration, Alternative Dispute

Resolution, Cyber Law, and Environmental Law. She completed her Master’s in Law from Queen

Mary University of London and the National Law School of India University. Her doctoral research

specializes in the domain of International Arbitration. https://orcid.org/0009-0005-3131-5034

The nations across the globe continue to struggle due to lasting impact of Covid-19

pandemic. This has resulted in the weakening of the commercial relationship between

the countries. To enhance investors’ participation, it is must that its dispute resolution

mechanism should be effective in reality. International arbitration has been a great

support in strengthening relationships with investors. Unfortunately, this pandemic has

disrupted many nations’ FDI inflow in the last two years. The 2022’s FTI Consulting report

has reflected on the changes which have been incorporated into the international

arbitration practice after this pandemic.

This paper will demarcate the current trends which have been followed across different

industries and geographies to indulge in international arbitration practice. Queen Mary’s

2021 International Arbitration survey has shown the various factors which have affected

the positioning of the “destination seat”. Welcoming technology in arbitration would be

beneficial for accepting it as the mode for settling disputes. This will guide the nations in

improving their performance and will be maintaining their contractual obligations. The

developing economies must indulge in such practices to overcome their challenges. By

maintaining ethnic diversity and security the parties would be able to maintain

international standards for fostering global relations.

Introduction

Since the world is hit by economic and financial loss by the Covid-19 pandemic investors’

participation has been very limited. With a huge amount at stake, the cross-border

relationship has been impacted by this pandemic which has resulted in disputes between

the parties. International arbitration practice has been beneficial in resolving matters

confined to trade activities. To maintain and enhance GDP it is essential to indulge in

those activities which are useful in maintaining economic balance. The World Bank has

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e-ISSN: 1647-7251

VOL 17, Nº. 1

May 2026, pp. 658-666

Shaping Global Relations Through International Arbitration: Recent Trends and Options

Misha Bahmani

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reflected that in 2022 the world trade volume will be surging to almost seven percent.

IMF data has depicted that cross-border trade concerning goods would rise to seven

percent. This demarcates that it is crucial that FDI inflow should be improved to enhance

the financial stability of the nations.

The filing of international arbitration has been

affected by this pandemic. There has been a surge in the average value of claims in 2020.

For instance, the German Arbitration Institute in 2020 recorded the average value of

claims to EUR 13.9 million as compared to EUR 3.8 million four years back.

Unfortunately, due to a lack of transparency and inconsistency, there has been difficulty

in tackling investment matters.

The 2020’s Queen Mary survey has demarcated that ISDS requires changes for more

efficiency which has gained seventy-five percent acceptance from the investors.

This

shows that resolving investor and State matters mode of dispute resolution has been

playing a meaningful role worldwide. Post-Brexit has resulted in the formation of a new

agreement between the EU and the UK to enhance investor participation.

To maintain

economic standards, it is symbolic to maintain growth in international arbitration

practice. The 2021’s International Arbitration survey has reflected the current adaption

and the upcoming changes which are preferred by the users. This survey depicts the

trends which are prevailing in the business community to resolve their commercial

disputes. For instance, London and Singapore are among the most approachable seat for

arbitration lately. To maintain neutrality judicial support has been beneficial which has

resulted in proper award enforcement.

In the near future client meeting by online mode

and encouraging the practice of paperless work to require the assistance of trained

persons to attain its sustainable development goal.

Before this pandemic international

arbitration was still considered to be the preferred way for solving cross-border matters.

Forty-eight respondents supported this viewpoint in 2018’s Queen Mary survey.

attain the goal of speedy relief, privacy, enforceability, flexibility, and neutrality this

practice is appreciated worldwide.

Geographies

Sadly, UAE legal system has been lacking in establishing a federal arbitration law. There

have been circumstances that reflect that the court has received uneven applications and

IMF, WORLD ECONOMIC OUTLOOK xvi (1

ed. 2021).

World Investment Report 2021, UNCTAD, (2021), https://unctad.org/system/files/official-

document/wir2021_en.pdf.

International Arbitration after the pandemic, FTI CONSULTING, (2022), https://www.fticonsulting.com/-

/media/files/emea--files/insights/reports/2022/apr/international-arbitration-after-

pandemic.pdf?rev=99711bd4cbed4c0aac79a728e96a7144&hash=434F6C319A7AC48D1943F0AC3A3B1F75.

2020 QMUL-CCIAG Survey: Investor’s perceptions of ISDS, ARBITRATION QMUL, (2020),

https://arbitration.qmul.ac.uk/media/arbitration/docs/QM-CCIAG-Survey-ISDS-2020.pdf.

Kirstin Schwedt et al., Investment protection in the EU-UK trade and cooperation agreement, KLUWER

ARBITRATION BLOG (Jan. 9, 2021), http://arbitrationblog.kluwerarbitration.com/2021/01/09/investment-

protection-in-the-eu-uk-trade-and-cooperation-agreement/.

2021 International Arbitration Survey: Adapting arbitration to a changing world, ARBITRATION QMUL, (2021),

https://arbitration.qmul.ac.uk/media/arbitration/docs/LON0320037-QMUL-International-Arbitration-Survey-

2021_19_WEB.pdf.

Id.

2018 International Arbitration Survey: The Evolution of International Arbitration, ARBITRATION QMUL, (2018),

https://arbitration.qmul.ac.uk/media/arbitration/docs/2018-International-Arbitration-Survey-report.pdf.

Id.

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e-ISSN: 1647-7251

VOL 17, Nº. 1

May 2026, pp. 658-666

Shaping Global Relations Through International Arbitration: Recent Trends and Options

Misha Bahmani

660

enforcement proceedings have been time-consuming.

This shows UAE’s legal

framework governing arbitration practice hasn’t been insufficient in addressing modern

arbitration practices.

The setting up of “Dubai International Financial Centre” along with

LCIA and “Emirates Maritime Arbitration Centre” shows a well-organized initiative to

have better performance. In 2019 there has been a twenty-nine percent surge in the

number of cases filed which shows better performance than the previous year.

Recently

in 2021, an ICC case management office has been opened in their global market.

Since

a year has passed it has been managing ICC arbitration users in the GCC. Due to the

Covid-19 impact and economic influence, there has been a surge in cases in GCC which

are required to be handled with care for maintaining their damages viewpoint.

Under the African practice, there has been a jump in the number of cases that have been

resolved through the arbitral centers. Welcoming acceptance has been given to

arbitration mode for resolving disputes by the parties. There has surge in arbitral centers

in Africa which shows that this mode is gaining recognition in this nation. The lawyers

have been indulged in attaining the skills which are essential for the successful delivery

of arbitration practice.

There are several States which are following the BITs and are

facilitating resolving the disputes between the investors and States by this mode. Being

a signatory to ICSID many states are obeying its guidelines.

There have been twenty-

seven percent progress in the registered cases by following this Convention and its facility

rules.

This shows that the parties from this nation’s States have increased to seven

percent and have indulged in ICC arbitration practice.

The European practice reflects that disputes concerning the UK and EU are governed by

the “Hague Choice of Court Agreements Convention”. After departing from the EU now

the UK still follows this framework for having court judgment enforcement. Although it

has its limitation as it applies only to the exclusive jurisdiction clauses.

London is a

“destination seat” and is in process of introducing trade agreements it would be required

to be observed if they cover ISDS than relying on BITs for protection.

With well-

established centers, the UK has been a preferable option for the parties. As there has

Supra note 3.

H Al Mulla and A Mackenzie, UAE approves New Federal Law on Arbitration, GLOBAL ARBITRATION NEWS

(Mar. 19, 2018), https://www.globalarbitrationnews.com/2018/03/19/uae-approves-new-federal-law-on-

arbitration/.

Supra note 3.

ICC Court to open 5

oversea case management office in ADGM, ICCWBO (Dec. 21, 2020),

https://iccwbo.org/media-wall/news-speeches/icc-court-to-open-5th-overseas-case-management-office-in-

abu-dhabi-global-market/.

M Ostrove et al., Developments in African Arbitration, GLOBAL ARBITRATION REVIEW (May 10, 2018),

https://globalarbitrationreview.com/review/the-middle-eastern-and-african-arbitration-

review/2018/article/developments-in-african-arbitration.

Hartwell, Norton Rose Fulbright International Arbitration Report, NORTON ROSE FULBRIGHT, (2019),

https://www.nortonrosefulbright.com/-/media/files/nrf/nrfweb/knowledge-

pdfs/emea_15747_newsletter__international-arbitration-report-_issue-

13.pdf?revision=&revision=4611686018427387904.

The ICSID Caseload- Statistics: Issue 2021-1, ICSID WORLD BANK, (2021),

https://icsid.worldbank.org/sites/default/files/publications/The%20ICSID%20Caseload%20Statistics%20%28

2021-1%20Edition%29%20ENG.pdf.

ICC Dispute Resolution 2020 Statistics, NYIAC, (2020), https://nyiac.org/wp-content/uploads/2021/09/ICC-

Dispute-Resolution-2020-Statistics.pdf.

Supra note 3.

International Arbitration in 2021, FRESHFIELD BRUCKHAUS DERINGER, (2021),

https://www.freshfields.com/4925a6/globalassets/our-thinking/campaigns/arbitration-

10kt/08486_pg_dr_international-arbitration_interactive_aw.pdf.

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been a surge in the caseloads performed by these centers.

They are not only confined

to Covid-19 concerned matters but they are covering issues confined to ESG matters

too.

There have been changes introduced in the arbitral rules of LCIA and ICC which

shows these centers are keeping themselves updated despite having a competition with

other centers.

In the North American context recently the USMCA has been introduced and NAFTA has

been replaced by it.

As per the new practice now USMCA has provided ISDS a limited

approach to some sectors and it is not providing between the US and Canada. This

agreement gives a restricted scope concerning investment protection confined to Mexico

and the US. Although it is not facilitating foreign investors which is a matter of concern

as it is limited to NAFTA. With the Covid-19 pandemic, there has been the utilization of

technology to perform the procedure. The remote hearing has been welcomed across the

nation it can be seen even today that this practice is still in continuation.

Interestingly, Brazil has been among the Latin nations which have been contributing the

second highest nationality where parties have shown their participation in ICC cases.

There has been a climb in arbitral institutions and as a result of ICC’s office and case

management, their performance has been improved.

The EU- Mexico free trade

agreement has been brought into practice which will be beneficial for the appealing

process and transparency in the arbitration mechanism.

Recent Trends

Under the energy sector, it has been noted that forty-one percent of cases were

considered under ICSID. Twenty-six percent of the caseload in LCIA is confined to this

sector.

Since European nations have increased their energy transition there have been

changes brought in the real practice which has resulted in a surge in disputes. Switching

to gas, the conflict between Ukraine and Russia has impacted the relationship in this

sector. The primary energy has become costly and the contractual obligations have

changed after these unfriendly events. Due to fluctuations in energy prices, there has

been a surge in investment and contractual disputes. With stranded assets and

participation, the sector is exposed to more risks and failures which has resulted in

unhealthy ends. Maintaining the practice of healthy climate change the governments are

making amendments to their policies which have contributed rise in global disputes.

Due to social distancing and restrictive movement during this pandemic there has been

a surge in material prices, profits have been reduced and financial instability has arisen

Supra note 3.

Id.

Trends in International Arbitration, BURFORD CAPITAL (2022),

https://www.burfordcapital.com/insights/insights-container/burford-quarterly-2022-arbitration-trends/.

Supra note 3.

Id.

Alison Ross, ICC opens hearing centre in Sao Paulo, GAR (Mar. 16, 2018),

https://globalarbitrationreview.com/article/icc-opens-hearing-centre-in-sao-paulo.

EU and Mexico announce the Finalization of an updated Free Trade Agreement, AKINGUMP (Apr. 29, 2020),

https://www.akingump.com/en/news-insights/eu-and-mexico-announce-the-finalization-of-an-updated-free-

trade-agreement.html.

LCIA Annual Casework Report 2020, LCIA (2020), https://www.lcia.org/News/lcia-news-annual-casework-

report-2020-and-changes-to-the-lcia-c.aspx.

Supra note 3.

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under the activities of this sector. Financial distress has impacted cross-border

construction projects which have resulted in a climb in construction disputes.

It is

expected that in the coming years under the natural resource sector there would be a

rise in resource nationalism.

This would result in the highest risk under this aspect as

these resources are now under government control. The policies and regulations are

formulated in such a manner that future projects would come across resource nationalism

at its extreme. While focusing on ESG it is expected that the supply and its security would

be affected. For instance, in the mining sector, there are chances that there would

increase in matters related to this sector.

This shows that geographical competition

would rise due to the difficulties which have arisen due to this pandemic. The 2022’s FTI

Consulting report depicts that there will be an imbalance of power, complexity in

agreements and joint ventures, and investment participation will be affected under such

circumstance arbitration practice would be a great support to resolve their concern.

In sectors such as the financial market due to the complexity of the disputes, arbitration

has been preferred since the arbitration clause has been the common practice under

financial matters. Brexit and LIBOR interest discontinuation after this pandemic has

resulted in a surge in participation in the travel and financial market which has considered

arbitration to resolve their issues. Matters confining to confidentiality, specialized

arbitrators, and speedy redressal have been among their prime concerns. With a panel

of recognized international market experts in the finance sector, it has published its new

arbitral rules for maintaining commercial ethics.

This reflects that international

arbitration forums are beneficial in governing financial instrument documentation.

Significantly, with the support of the national legal framework IP rights, it becomes the

responsibility to handle multi-State matters to safeguard these rights. ADR guidelines by

WIPO have contributed to solving these matters through expert determination,

mediation, and good offices.

The 2022’s FTI Consulting report states that license fee

matters would be considered to be resolved by international arbitration as it involves a

huge amount at stake concerning the patents.

Further, ICDR has allowed the tribunal

to set the arbitration’s cost and apportion that reflects the arbitrators under this would

be compensated by hourly rate.

The ICC court plays a remarkable role in ensuring the

ICC’s rules implementation through arbitration.

Supra note 3.

J Blanco and M P Machado, Resource Nationalism surges in 2020, Covid-19 worse outlook, MAPLE CROFT

(Mar. 4, 2021), https://www.maplecroft.com/insights/analysis/resource-nationalism-surges-in-2020-covid-

19-worsens-outlook/.

Resourcing the Energy Transition: Making the World go round, KPMG INTERNATIONAL (2021),

https://home.kpmg/ky/en/home/insights_new/2021/03/resourcing-the-energy-transition.html.

Supra note 3.

Ian McDonald et al., Prime time for updated arbitration rules for financial disputes? A review of the P.R.I.M.E

Financial Arbitration Rules 2022, MAYER BROWN (Jan. 5, 2022),

https://www.mayerbrown.com/en/perspectives-events/publications/2022/01/prime-time-for-updated-

arbitration-rules-for-financial-disputes-a-review-of-the-prime-finance-arbitration-rules-2022.

WIPO Caseload Summary, WIPO (2021), https://www.wipo.int/amc/en/center/caseload-2021.html.

Supra note 3.

IDRP art. 37 (2021).

David Salton, Recent trends in International Arbitration and 2021 International Rule, CONSTRUCTION LAW

JOURNAL 81, 83 (2022).

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Shaping Global Relations Through International Arbitration: Recent Trends and Options

Misha Bahmani

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Current Options

The 2021’s Queen Mary survey depicts that ninety percent of the respondent have

preferred international arbitration mode for resolving cross-border matters. This shows

that the support of local courts and judicial encouragement has been made to prevail

neutrality and impartial practice in the legal system. Making the arbitration rules and

institutions inviting requires administrative support.

Thirty-two percent of respondents

have agreed that with administrative strengthening the virtual hearings will become more

approachable.

This survey has shown that to make institutions or rules alluring for the

users it is essential that there should be arbitrators belonging to different diversity.

Twenty-four percent of the respondent have consented that with the support of a well-

structured procedure multi-party and complex matters can be taken into consideration.

By incorporating provisions for conducting in-person and virtual hearings the arbitral

process will be smoothly conducted. In this survey, twenty-three percent of the

respondent supported this viewpoint. Twenty percent of the respondent have stated that

by having adequate electronic filing and document-sharing facilities the process can be

more convenient. Interestingly, it is suggested that there should provision confining to

expedited procedures. Almost twenty-five percent of the respondent supported this

change should be introduced in the practice. There should be cost sanctions related to

delay by the arbitrators which have been recommended by twenty-one percent of the

respondent in this survey. To enhance the case management practice rules should be

made to provide power to the arbitrators. This shows parties’ and counsel’s behavior has

to be as per the directions of these rules.

These are the choices that are reflected recently by this survey to make international

arbitration practice flexible and party autonomy prevails properly. The adaption requires

to be a welcoming step to enhance cross-border transactions. In this, the respondent has

expressed their concern about avoiding having lengthy written submissions. Sixty-one

percent of respondents agreed with this approach. Thirty-eight percent supported the

concern that while addressing procedural matters oral hearing can be excluded.

sacrifice the practice of document production was agreed by the twenty-seven

respondent. This survey has shown that in-person hearing can be less encouraged.

Twenty percent of respondents shared that now users are similar to virtual hearing. There

should be a removal of early case management conferences. Fifteen percent supported

the view that there should be no cross-examination. Further, thirteen percent said no to

party-appointed experts as it can be used as a mode for creating pressure. In this survey,

it has highly suggested that to maintain flexibility it is essential to be cost friendlier steps

to have greater efficiency. There has been an improvement in gender diversity. Fifty-six

percent of respondents agreed that this has been beneficial for maintaining impartiality

and neutrality in the process.

Encouragement has been made to utilize cloud-related storage. Among them, eighty-

seven percent agreed that if offline hearing can’t take place online would be preferred.

Supra note 6.

Id.

Supra note 6.

Id.

Supra note 6.

JANUS.NET, e-journal of International Relations

e-ISSN: 1647-7251

VOL 17, Nº. 1

May 2026, pp. 658-666

Shaping Global Relations Through International Arbitration: Recent Trends and Options

Misha Bahmani

664

Such a process has resulted in maintaining greater efficiency, and diversity in the arbitral

process. Due to online hearings, the arbitrators can attain dates and in this survey, sixty-

five percent of respondents supported it. There is a need to focus on the adoption of soft

laws which promote the practice of green arbitration. The “green pledge” needs to take

seriously by the arbitrators. Carbon offsetting requires to be reduced which can be

possible if there is less traveling and more hearing by online mode.

Challenges

Unfortunately, one-third of the respondent have expressed their concern that there is a

requirement to improve ethnic diversity. It is the responsibility to carry the onus of

enhancing diversity through their arbitrator choices. Since still thirty-four percent have

emphasized that there is no growth done concerning ethnic diversity reflects that there

is a necessity to have improvement.

It is found that AI still requires improvement in

arbitration practice. Users were forced to adapt to online hearing during the Covid-19

pandemic. One needs to understand that AI can’t substitute for human arbitrators as

well as counsel. There is a requirement to maintain confidentiality and cybersecurity

needs to prevail properly. The arbitrators online do come across online disturbances while

proceeding with the online mode. Due to variations in time zones arranging the online

hearing has been a difficult task. Virtual hearing has its difficulties during and after this

pandemic.

To improve visibility, it is essential to indulge in awareness camps focusing on promoting

and educating students. To build proper visibility more mentoring programs should be

organized to train the arbitrators.

Appointing authorities as well as institutions that

follow an express policy for incorporating suggestions and appointing candidates

belonging to larger diversity should be given the responsibility of an arbitrator. In 2021’s

Queen Mary survey fifty-nine percent of respondents admitted to this practice and forty-

six have shown their consent that there should be counsel which would emphasize

engaging the clients to appoint arbitrators belonging to greater diversity.

To keep

interactions engaging forty percent of the respondent have agreed to conduct substantive

hearings in person and virtual way. Of this sixty percent have supported that post covid

client meetings would take place in offline and online modes. This depicts that the best

interest of the client should be the priority of the arbitrators to follow any form the

arbitration practice. There is a need to have reliability on technology, be environment

friendly, express provisions in rules and laws to provide recognition to online hearings,

and good quality hearings are the fundamental requirements which are required to be

fulfilled in near future.

Id.

Supra note 6.

Id.

Supra note 6.

Id.

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e-ISSN: 1647-7251

VOL 17, Nº. 1

May 2026, pp. 658-666

Shaping Global Relations Through International Arbitration: Recent Trends and Options

Misha Bahmani

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Future Trends

To make a nation arbitration friendly there are countries that are encouraging resolving

ESG matters. It is expected that with a surge in contractual disputes in near future it can

be under this ambit. The disputes between States and investors focusing on ESG aspects

are among the new trends in international arbitration practice.

Also, in the future third-

party funding is expected to enhance its strength. There is a need to have clarity

concerning alternative means for maintaining investors’ protection. With an objective to

maintain standards ICCA’s Guidelines and Code of Conduct meant for Adjudicators

concerning global investment matters are published recently in 2021. This encourages

the practice to maintain uniformity in its implementation. By creating awareness about

the investment treaty focus has been made on encouraging a platform for their

protection. It has welcomed blockchain, AI, and cryptocurrency matters which can be

addressed under tech issues through arbitration. Investment treaties are helpful in

creating a developed banking community that can prevail by incorporating arbitral

procedures in these matters. Since there has been involved in renewable as well as low

carbon projects if an issue arises it can be addressed under the ambit of construction

arbitration which in the coming years requires assistance while focusing on new

technology and its impact on the climate. This display that it is predicted that these

practices will be constructive in strengthening international arbitration practices across

the globe.

This shows that in the future the clients and the arbitration community

would be engaging in these trends in much more depth and would have their own

challenges with the passage of time which requires adequate monitoring and

implementation of the new rules to maintain investors friendly relationships.

There has been a surge in caseloads which has indulged arbitral institutions in initiating

funding and focused on adopting financial rules globally. For instance, ACICA has

welcome third-party funding. A reasonable disclosure rule meant for third-party funding

has been adopted by ICC. In nations like Latin America, the ECLAC has estimated that

there will be a fall in its average growth in 2021. For nations that are facing oil and gas

issues such as Bolivia and Venezuela, it is expected these disputes can be resolved by it.

Due to complex issues and investors’ protection international arbitration would be a great

support.

To be a “destination” seat international arbitration must have effective

sanctioning during the arbitral process and power should be vested in third parties.

Providing recognition to the seat and maintaining an impartial practice in the local legal

mechanism would be beneficial in making a seat desirable.

Conclusion

The Covid-19 pandemic has brought instability and has led to restrictions in supply which

have resulted in the cancellation and postponement of projects. Since most of the sectors

were badly affected by this pandemic the parties weren’t able to fulfill their contractual

obligations. This has resulted in impacting the connectivity between them. As a result,

Ashley Jones, International Arbitration in 2022: Top Trends, LEXOLOGY (Feb. 7, 2022),

https://www.lexology.com/library/detail.aspx?g=41db7bca-0ee0-4685-9250-22cdcaf5e399.

Supra note 50.

Supra note 22.

Supra note 8.

Id.

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there has been a surge in these matters, and the relationship between the investor with

the State has been put at stake. Cross-border issues are expected to have risen and

international arbitration will be the most preferred way to resolve these disputes. The

“new normal” practice has been welcomed worldwide across many nations which have

considered this method to be efficient and cost friendlier to facilitate its process. With a

rise in complexity in the economy in the near future, the output and investment flow are

expected to get worse under such circumstances arbitral institutions would play a

significant role.

There has been a surge in international arbitration filing till 2020 but

unfortunately, with this pandemic, the FDI flow has fallen and the nations are now making

an effort to recover from its impact. With the reform of ISDS and EU emphasis has been

made on establishing an investment court which would be beneficial for gathering growth

in international commercial activities.

With 2021’s ICC rules emphasis has been made

on preventing conflicts of interest. This has resulted in developing the relationship

between the arbitrators as well as new representatives.

In the arbitral panel, there is a

need to promote diversity for which among the counsel team there is a requirement of

promoting diversity.

Users should be updated with transformative technology. The

green arbitration practice would be beneficial in attaining the goal of sustainability. To be

a desirable seat it is necessary that the seat must comply with all the valuable traits of

international arbitration which would promote addressing cross-border issues amicably.

AI utilization has been appreciated globally for specific tasks for enhancing international

relations

How to cite this note

Bahmani, Misha (2026). Shaping Global Relations Through International Arbitration: Recent Trends

and Options. Janus.net, e-journal of international relations. VOL. 17, Nº. 1, May 2026, pp. 659-

666. DOI https://doi.org/10.26619/1647-7251.17.1.02

Supra note 3.

Id.

Salton, supra note 37.

Supra note 6.

Annual Arbitration Survey 2023: The rise of machine learning, BCLP (2023),

https://www.bclplaw.com/a/web/tUW2SW6fjHrpXVrA7AfWkS/102932-arbitration-survey-2023-

report_v10.pdf .