Domestic Courts' Impact on Arbitral Awards: Pragmatic Reflections on the New York Convention

On June 1, 2018, the heirs of the late Sheikhs Abdullah Al-Solaiman AlHamdan and Khalid Abu Al-Waleed Al-Oarqani ("Claimants") petitioned to confirm and enforce an $18 billion arbitral award against Chevron entities before the Northern District of California and the Southern District of Texas. The award was issued under the auspices of the illegitimate "International Arbitration Centre" ("IAC") in Cairo, Egypt. The dispute involved a decades-old concession agreement in which the Saudi government permitted Chevron's predecessor, the Standard Oil Company of California ("SoCal"), to develop certain Saudi oil fields. Both enforcement petitions were dismissed.