Key features of new SIAC Rules 2025 and practical tips ~Insights from Global Arbitration Practitioners on different arbitration practices and laws in Singapore, Hong Kong, London, Germany, Japan.

When arbitration is selected as a dispute resolution procedure in international transaction contract, the parties will agree on the governing law, seat of arbitration, arbitration institution, etc. in an arbitration agreement. However, arbitration agreement clauses tend to be disregarded in negotiations for international transaction contracts, and there are many cases in which the party merely accepts the arbitration agreement clauses presented by the other party as they are under the pressure of concluding the contract promptly. However, the choice of the governing law, seat of arbitration, arbitration institution, etc. can have a significant impact on the nature of the arbitration proceedings in the event of an actual dispute, specifically the costs and time required for arbitration proceedings, and even the outcome of the award.

Unlike court proceedings, arbitration proceedings are a procedure that can be designed by the user, and it is possible to design an arbitration system that is appropriate for the case by strategically selecting the governing law, seat of arbitration, arbitration institution, etc. at the time of the arbitration agreement. It is important to draft and negotiate arbitration agreement clauses with an understanding of how the choice of governing law, seat of arbitration, arbitration institution, etc. will make a difference in the arbitration proceedings. However, there is not much literature written on these differences on an honest basis.

The seminar will provide tips on how to make the most of the new SIAC Arbitration Rules, which were just amended in January 2025, and by inviting Mr. Siegfried Elsing who has handled over 300 arbitration cases as an internationally renowned arbitrator, and Mr. Robert Pé who has served as arbitrator in arbitrations under various governing laws, arbitration institutions and seats of arbitration, will discuss the choice of governing law, seat of arbitration, and arbitration institution from the perspective of common law and civil law, as well as their experiences as arbitrators and arbitration representatives, and will provide useful perspectives and concrete know-how.