SIAC arbitration

The Singapore International Arbitration Centre and its arbitration rules

The Singapore International Arbitration Centre (SIAC) is an international arbitral institution established in 1991. SIAC is an independent, non-profit organisation that provides case management services for administering arbitrations. Its primary functions involve appointing arbitrators or a panel of arbitrators and managing the arbitral process on behalf of parties to an arbitration. SIAC provides a neutral, efficient and reliable service for resolution of disputes.

SIAC’s popularity as an international arbitral institution is underpinned by Singapore’s policy of supporting international arbitration. The Singapore government has repeatedly emphasised its commitment to developing Singapore as an arbitration hub, and Singapore’s courts have maintained a juridical

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Who decides what? Clarifying the boundaries of Appellate Control over Exequatur in France(France – Federative Republic of Brazil (União) v [J])

Arbitration analysis: On 8 January 2026, the Paris Court of Appeal, sitting through the conseiller de la mise en état, held that it lacked jurisdiction to determine the admissibility of a plea seeking annulment of an exequatur order on the basis of an alleged excess of power of the first-instance judge. According to the court, such a plea concerns the appeal itself and therefore falls within the jurisdiction of the Court of Appeal sitting as a full bench, rather than that of the conseiller de la mise en état acting alone. The order was made in proceedings concerning the exequatur in France of a partial award rendered in São Paulo under the auspices of the Câmara de Arbitragem do Mercado (CAM), in a shareholder dispute between minority shareholders of Petrobras and the Federative Republic of Brazil (the União). Although the ruling addresses a strictly procedural issue, it usefully clarifies the allocation of functions between the pre-trial judge (conseiller de la mise en état) and the appellate bench in proceedings brought against exequatur orders under article 1527 of the French Code of Civil Procedure. It confirms that a procedural argument seeking to invalidate the appeal (fin de non-recevoir), where that argument is in fact tied to the substance of the appeal itself, must be decided by the full bench and cannot be filtered out by a single judge at the pre-trial stage. The ruling therefore has practical implications for how parties should frame and time their procedural arguments in exequatur-related appeals. Written by Marie-Laure Cartier and Alexandre Meyniel, partners at Cartier Meyniel AARPI with Sami Kabbara, trainee lawyer at the Paris Bar Centre and intern at Cartier Meyniel AARPI.

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