Duty and discretion in international arbitration

International arbitration implicates complex relationships between the plac e of arbitration and the location of the party's assets, which have been hi ghlighted by cases recognizing foreign awards despite their vacatur at the arbitral situs. The author examines the extent to which enforcement of vaca ted awards comports with the parties' expectations and arbitration's treaty framework. The author suggests that the United States enact a statute clar ifying the role and scope of federal judicial supervision of international commercial arbitration.