24 United States As mentioned, the New Law is largely based on the UNCITRAL Model Law of International Commercial Arbitration. Major similarities can be seen, such as the adoption of the UNCITRAL Model Law’s definition of “international arbitration”. However, despite aligning with international standards, the New Law introduces innovative and unique approaches suitable to the Israeli context and its specific business needs. The Israeli Law differs from the UNCITRAL Model Law in several aspects, yet it upholds the core principles of the Model, ensuring consistency with its underlying framework. Unlike the Model Law, which prohibits appeals of certain court decisions such as the appointment or disqualification of arbitrators and the tribunal’s jurisdiction, the New Law permits parties to request court approval for appeals in these cases. Additionally, the Israeli Law limits arbitrators to issuing interim orders rather than preliminary ex-parte orders, unless the parties explicitly agree otherwise. These adaptations aim to provide a balance between procedural flexibility, party autonomy and the integrity of arbitration proceedings. The New Law also includes provisions that enable the recognition and enforcement of foreign arbitral awards, in accordance with the 1958 New York Convention. For example, Section 44(a) of the New Law reflects Article III of the Convention, treating foreign arbitral awards as binding and enforceable under local law. Similarly, Section 43 matches Article V of the Convention, outlining grounds for refusing recognition or enforcement of arbitral awards, whether foreign or domestic. However, the Israeli Law goes further by including procedural adaptations, such as clear deadlines for submitting requests and granting Courts the authority to suspend annulment proceedings. Article 3 states that matters addressed by the New Law, which are also governed by an international treaty to which Israel is a party, such as the New York Convention, will be regulated and resolved in accordance with the provisions of the particular treaty. Europe Europe has a lengthy tradition of arbitration, influenced heavily by the principles laid out in the UNCITRAL Model Law on International Commercial Arbitration and 1958 New York Convention, which many European countries have adopted or used as a reference for their own laws. Key features in the European Laws relate, among others, to the ability of arbitrators to decide on their own powers, the limited scope of Court intervention and the recognition
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