1 555 F. Supp. 481 (D.V.I. 1982).

2 June 10, 1958, 21 UST 2517, TIAS No. 6997, 330 UNTS 38.

3 712 F.2d 50, 53.

4 The court observed that a proposal entertained during the treaty negotiation to incorporate in Article II choice-of-law language similar to that in Article V was rejected by the drafters, who “were concerned that a forum might then have an obligation to enforce arbitration clauses regardless of its ‘local’ Law.” Id.

5 Id, (citations omitted). See Scherk v. Alberto-Culver Co., 417 U.S. 506, 530 n.10 (1974).

6 712 F.2d at 54.

7 Article V §l(d) permits refusal of enforcement if “[t]he composition of the arbitral authority or the arbitral procedure was not in accordance with the agreement of the parties, or, failing such agreement, was not in accordance with the law of the country where the arbitration took place.”

8 712 F.2d at 54.

9 See, e.g., Sanders, , A Twenty Years’ Review of the Convention on the Recognition and Enforcement of Foreign Arbitral Awards, 13 Int’l Law. 269, 271 (1979)Google Scholar: “[I]n 100 cases applying the New York Convention, enforcement has been refused for reasons of public policy only three times.” The three cases denying enforcement dealt with violations of the forum state’s public policy that were far more substantive than procedural.

10 Id. at 286.