Abstract
The global landscape of international commercial arbitration is currently undergoing a structural transformation characterized by a “polycrisis” of macroeconomic shocks and geopolitical realignments. Authored by Judge Nazmul Hasan, an expert in the field and Senior Judicial Magistrate, this article examines how systemic instability between 2020 and 2025 has dislodged traditional assumptions of stable supply chains and neutral dispute resolution frameworks.
Through an empirical analysis of institutional caseloads, the study highlights a qualitative shift toward high-value, complex disputes, noting the surge in aggregate dispute values at the ICC to $102 billion alongside the rapid growth of Asian arbitral hubs like CIETAC and HKIAC. The article further explores the “weaponization” of trade policy, specifically the 2025 “tariff tsunami” and the emergence of “Trump measure clauses” in contractual drafting to mitigate policy volatility.
It identifies significant procedural hurdles posed by global sanctions—termed a procedural “obstacle course”—and a burgeoning “integrity crisis” driven by nationality-based bias in jurisdictions such as Russia. Finally, the work maps the shifting geography of arbitration toward neutral and “tech-ready” seats like the UAE and the localized ecosystems of the AfCFTA, concluding that the future of the field depends on its ability to maintain legitimacy in a fragmented, multi-polar global order.
Keywords
International Commercial Arbitration, Geopolitical Tensions, Trade Policy, Polycrisis, Institutional Caseloads, 2025 Tariffs, Trump Measure Clauses, Economic Sanctions, Nationality-Based Bias, Arbitrator Neutrality, UAE Arbitration Reform, AfCFTA Investment Protocol, Semiconductor Disputes, Force Majeure, Hardship Doctrines, CISG, New York Convention Enforcement, Public Policy Exception, AI Adjudication, ESG Disputes.
Introduction
The global landscape of international commercial arbitration has entered a period of structural transformation, driven by a convergence of macroeconomic shocks and geopolitical realignments that commentators have termed a “polycrisis”.1 Between 2020 and 2025, the assumptions underpinning global commerce—predicated on stable supply chains, predictable regulatory environments, and a neutral judicial or quasi-judicial framework for dispute resolution—have been fundamentally dislodged.1 The international arbitration community, traditionally a bastion of neutrality and procedural consistency, now finds itself at the epicenter of these shifts, grappling with record-high caseloads, unprecedented jurisdictional conflicts, and the weaponization of trade policy.3
As geopolitical instability becomes a permanent catalyst for disputes across the energy, construction, transport, and technology sectors, the practice of arbitration is evolving to maintain its legitimacy.2 This evolution is marked by:
- A deepening market share for institutions in particular regions.
- A surge in the financial stakes of disputes.
- Increased reliance on arbitration to navigate the fallout of trade wars and aggressive sanction regimes.5
Institutional Caseloads and the Empirical Reality of Global Disruption
The empirical evidence of the impact of geopolitical tensions is most starkly reflected in the record-breaking caseload statistics of the world’s leading arbitral institutions.3 In 2024, the total number of newly initiated cases across major researched institutions increased to 10,067, up from 9,388 in 2023.6 This rise is not merely a quantitative increase but signifies a qualitative shift toward higher-value, more complex disputes that reflect the systemic risks of the current era.5
Comparative Institutional Caseload and Dispute Values (2023–2024)
The following table illustrates the divergence in institutional performance, highlighting the growth of Asian centers and the increasing financial stakes in traditional European and American hubs.5
| Arbitral Institution | 2023 Case Volume | 2024 Case Volume | Growth/Change | 2024 Aggregate Dispute Value (USD) |
|---|---|---|---|---|
| CIETAC | 5,237 | 6,013 | +14.82% | $26.57 Billion |
| ICC | 890 | 841 | -5.5% | $102 Billion (New) / $354B (Total Pending) |
| SIAC | 663 | 625 | -5.7% | Third busiest year on record |
| HKIAC | 281 | 352 | +25.26% | $11.8 Billion (Estimated Increase) |
| ICDR (AAA) | N/A | 811 | Steady | $4.8 Billion |
| LCIA | 327 | 318 | -2.7% | High complexity (claims >$10M) |
| SCC | 175 (Est.) | 204 | +16.5% | $15.93 Billion |
| Swiss Arb. Centre | 98 | 100 | +2.0% | Historical peak |
The data suggests that while the volume of cases at the ICC and SIAC saw a marginal dip, the aggregate value of disputes surged dramatically.5 At the ICC, the total amount in dispute nearly doubled from $53 billion in 2023 to $102 billion in 2024, while the total value of all pending cases reached an unprecedented $354 billion.5 This indicates that users are increasingly selecting arbitration for the most high-stakes, cross-border complexities where global enforceability is non-negotiable.5
Conversely, the remarkable growth of CIETAC and the HKIAC reflects a localized shift toward Asian seats, driven by the expansion of Asian economies and the strategic reallocation of Chinese Foreign Direct Investment (FDI) in response to Western trade barriers.1 The HKIAC’s 25% increase in case volume in 2024 mirrors its status as a primary hub for China-related disputes, particularly as geopolitical tensions complicate the selection of Western seats for Chinese entities.6
Trade Policies and the “Tariff Tsunami” of 2025
Perhaps the most disruptive force in the 2025 arbitral landscape has been the implementation of sweeping, reciprocal tariffs by the United States administration.3 These tariffs, some reaching levels not seen in a century, have injected acute uncertainty into cross-border commerce, forcing companies to re-evaluate long-term supply contracts and joint venture agreements.8
The Legality of Tariffs and Arbitral Stays
The implementation of country-specific tariffs under the International Emergency Economic Powers Act (IEEPA) has sparked intense legal debates.8 While these disputes are currently playing out in the U.S. court system—most notably in Learning Resources, Inc. v. Trump, which addresses whether the IEEPA unconstitutionally delegates legislative power to the President—the impact is already being felt in commercial arbitrations.8
Parties suffering from the impact of these tariffs are contending that the measures are ultra vires, fundamentally altering the economic basis of their contracts.8 In response, several arbitral tribunals have elected to stay tariff-related proceedings pending the U.S. Supreme Court’s decision, illustrating the direct link between constitutional law developments and the procedural efficiency of international arbitration.8
The Emergence of the “Trump Measure Clause”
In response to this volatility, a new trend in contractual drafting has emerged, colloquially referred to as “Trump measure clauses”.8 These provisions are increasingly integrated into commercial contracts and M&A agreements to mitigate the risk of sudden policy shifts.11 Unlike traditional, broad force majeure clauses, these specific provisions:
- Explicitly reference tariffs, trade sanctions, or specific governmental actions as triggering events.8
- Include structured renegotiation or price review triggers tied to defined tariff thresholds, such as a mandatory renegotiation if a tariff exceeds 20%.8
- Allocate the burden of import duties more precisely than standard Incoterms, anticipating the potential for sudden cost surges.8
In M&A contexts, these clauses may allow for the renegotiation of purchase prices or the termination of a deal if a trade policy shift materially alters the target’s economic profile between signing and closing.11
Cost Allocation and the Scrutiny of Incoterms
When contracts continue despite tariff increases, the primary point of contention is the allocation of these new costs.8 While U.S. customs law generally holds the importer of record responsible for paying duties upon entry, commercial contracts often contain pricing clauses or change-in-law provisions that can shift this burden.8 Arbitral tribunals are now tasked with providing a granular interpretation of these clauses, particularly when the contract is silent on the specific impact of extraordinary protectionist measures.8
| Contractual Clause | Impact Of 2025 Tariffs | Threshold For Relief |
|---|---|---|
| Force Majeure | Parties argue tariffs constitute an “unforeseeable governmental action”.8 | High; must typically render performance impossible or illegal.14 |
| Hardship | Allows for renegotiation when the economic balance is fundamentally upset.8 | Civil law jurisdictions may allow adjustment to restore equilibrium.8 |
| Price Review | Triggers an adjustment based on objective formulas or changes in circumstances.8 | Common in energy/commodities; depends on formula wording.8 |
| Change-In-Law | Covers new taxes or regulations imposed after contract signing.8 | Highly effective if “trade measures” are explicitly included.13 |
Sanctions As a Procedural “Obstacle Course”
The proliferation of sanctions, particularly following the invasion of Ukraine in 2022, has transformed international arbitration into a procedural “obstacle course”.16 Sanctions affect every stage of the process, from the ability to pay filing fees to the willingness of arbitrators to accept appointments.17
Logistical and Banking Hurdles
The 2025 International Arbitration Survey reveals that 27% of respondents have faced administrative and payment challenges due to sanctions.19 These challenges are not merely bureaucratic but can be fatal to the proceedings.
Key Sanctions-Related Challenges
| Challenge | Description | Impact on Arbitration |
|---|---|---|
| Banking Bans | Many banks refuse to process any payments related to a sanctioned entity, even for the payment of arbitral fees or legal costs. | Leads to delays or the inability to initiate proceedings.16 |
| Arbitrator Remuneration | Arbitrators may find their fees blocked or frozen. | Creates reluctance among arbitrators to accept nominations in cases involving sanctioned parties.17 |
| Legal Representation | Law firms must navigate complex licensing requirements to represent sanctioned clients. | Many firms decline such mandates due to reputational risks or the administrative burden of invoicing frequently to comply with 14-day credit limits.16 |
Access To Justice and Witness Testimony
Sanctions also restrict the physical movement of parties and witnesses. Travel bans may prevent key individuals from attending hearings in person, necessitating virtual formats.17 While virtual hearings have become a standard tool since the pandemic, practitioners note that the loss of interpersonal nuances can compromise the perceived fairness of the proceedings, especially in high-stakes cases where witness credibility is central.18
Furthermore, 25% of survey respondents reported difficulty finding counsel or experts able to participate, raising serious concerns about the principle of “access to justice” in the international legal order.19
The Integrity Crisis: Nationality-Based Bias and Arbitrator Scrutiny
One of the most profound impacts of geopolitical tensions is the heightened scrutiny of arbitrators’ backgrounds, nationalities, and even their public political stances.20 This has led to an increase in challenges and a narrowing of the pool of suitable candidates for sensitive disputes.20
Case Study: Russian Supreme Court Case No. А45-19015/2023
The Russian judiciary has pioneered a controversial legal position regarding arbitrator neutrality in the context of “unfriendly states”.20 On July 26, 2024, the Russian Supreme Court issued a landmark decision refusing to enforce an English arbitral award in S. Thywissen GmbH v. JSC Novosibirskhlebprodukt.21
The court ruled that if an arbitral tribunal is composed of nationals from countries designated as “unfriendly” by the Russian government, a “reasonable presumption of bias” is created.20
In this case, the tribunal included citizens of the United Kingdom, Ukraine, and Denmark — all of which are on the list of 49 countries deemed hostile.21 The court concluded that such a tribunal could not be viewed as impartial in a dispute involving a Russian party, effectively placing the burden on the party seeking enforcement to disprove this bias.20
Implications For The Future Of Commercial Arbitration
- Enforceability Risks: Awards rendered by tribunals with “unfriendly” nationals face significant risks of being set aside or denied enforcement in Russia.20
- Arbitrator Challenges: Parties are increasingly using an arbitrator’s nationality or their public statements (e.g., signing a declaration criticising a conflict) as a basis for challenge.20
- Strategic Seat Selection: Users are shifting away from traditional seats like London or New York to avoid these “nationality-based bias” presumptions, favoring seats in neutral jurisdictions like Singapore or the UAE.19
Variable Outcomes In Institutional Challenges
The treatment of these challenges varies significantly between institutions and ad hoc bodies.
| Institution / Forum | Case Development | Outcome |
|---|---|---|
| PCA Inter-State Dispute (Russia v. Ukraine) | Two arbitrators were challenged due to their support for an international law declaration criticizing the conflict. | Both arbitrators were removed in March 2024 as their statements were deemed to impair impartiality.20 |
| ICSID Case No. ARB/24/1 | A challenge was filed against a U.S. arbitrator on similar grounds. | The challenge was rejected in July 2024, demonstrating a different institutional approach.20 |
These contrasting outcomes highlight the lack of global consensus on how political views should impact an arbitrator’s mandate.20
The Shifting Arbitral Geography: Re-Alignment of Seats
Geopolitical alignments are actively redrawing the map of preferred arbitral seats.24 While London, Singapore, Hong Kong, and Paris remain dominant, the criteria for selecting a seat have evolved beyond mere judicial quality to include “sanctions neutrality” and “tech-readiness”.5
The Rise Of The UAE And The Middle East
The United Arab Emirates has emerged as a major beneficiary of these shifts, entering the ICC’s top five seats for the first time in 2024.5 This ascent is supported by a robust reform agenda:
- Legislative Updates: The UAE Federal Law No. 15 of 2023 emphasizes virtual hearings and modern electronic communications, positioning the region as a tech-forward hub.24
- Institutional Consolidation: The launch of ArbitrateAD (Abu Dhabi) and the modernization of DIAC (Dubai) have provided new, best-in-class rules that align with international standards.24
- Judicial Support: UAE courts have shown an increasing willingness to enforce foreign interim measures and respect the validity of arbitration agreements even after institutional mergers (e.g., the transition from DIFC-LCIA to DIAC).27
However, the UAE remains a complex seat due to strict rules on the “capacity of signatories”.26 In 2024, the Abu Dhabi Court of Cassation (ADCC Case No. 902/2024) annulled an award because a CEO signed the contract without express authorization in the articles of association, highlighting that procedural pitfalls still exist despite broader “arbitration-friendly” trends.26
The African Continental Free Trade Area (AfCFTA) And Sovereignty
In Africa, the AfCFTA Protocol on Investment (2023) is reshaping the continent’s approach to dispute resolution by prioritizing mediation and localizing arbitration.28 The Protocol aims to terminate intra-African BITs and move away from traditional Investor-State Dispute Settlement (ISDS) mechanisms that African states argue disproportionately favor foreign investors.28
A major shift in the Protocol is the replacement of the expansive “Fair and Equitable Treatment” (FET) standard with a more circumscribed “Administrative and Judicial Treatment” standard.29 This new standard is intended to prevent the “regulatory chill” that occurs when states fear large arbitration claims for enacting public interest policies.29
Feature Of AfCFTA Investment Protocol
| Feature Of AfCFTA Investment Protocol | Shift From Traditional BITs | Impact On Arbitration |
|---|---|---|
| BIT Termination | Terminates all existing intra-African BITs within 5 years.29 | Ends the era of “first-generation” treaties.31 |
| Treatment Standard | Replaces FET with “Administrative & Judicial Treatment”.29 | Narrows the scope for arbitrator discretion.29 |
| Dispute Mechanism | Prioritizes mediation and localized African centers (CRCICA, LCA, KIAC).28 | Reduces reliance on ICSID and European seats.28 |
| Sunset Clauses | Extinguishes survival clauses for intra-African treaties.29 | Provokes debate on “vested rights” of investors.29 |
The Technology Sector: Semiconductors And AI Chips
The U.S.-China strategic rivalry has turned the semiconductor industry into a primary battleground for trade-related arbitrations.7 Unlike traditional tariff disputes, the conflict in the technology sector is centered on export controls, intellectual property, and supply-chain chokepoints.32
Export Controls And “Weaponized Interdependence”
The U.S. has increasingly used the “Entity List” and the “Foreign Direct Product Rule” (FDPR) to sever Chinese firms from advanced semiconductor technologies.33 These measures force multinational corporations into an “innovation decoupling penalty,” where they must maintain duplicate supply chains and R&D efforts to comply with competing sovereign mandates.33
Disputes arising from these tensions often involve:
- Force Majeure And Illegality: Suppliers seeking to excuse non-performance because U.S. export licenses were denied for chips destined for China.13
- Joint Venture Withdrawals: Companies pulling out of Southeast Asian or Mexican hubs due to reorganized supply chain mandates, triggering claims for breach of investment agreements.9
- National Security Screens: Transactions being subject to retroactive divestment risks under CFIUS in the U.S. or the Digital Markets Act in the EU, even years after closing.11
Made In China 2025 And Retaliatory Measures
China’s “Made in China 2025” plan targets 70% self-sufficiency in core technologies, a goal that has funneled hundreds of billions into the sector and created a “techno-democratic bloc” vs. a “Chinese technological autonomy” bloc.33 China’s retaliatory economic statecraft, such as export controls on rare earth processing technologies, serves as a strategic signal that Beijing is willing to weaponize its own market power in response to Western restrictions.33
This synergistic effect of adversarial policies destabilizes the hyper-efficient global supply chain model, fueling sector-specific inflationary pressures and a surge in commodity-related arbitrations.33
Legal Doctrines In Flux: Force Majeure, Hardship, And The CISG
The interpretation of contractual performance excuses is undergoing a period of intense refinement by arbitral tribunals.14 As unforeseen events—from pandemics to full-scale land wars—become the norm, the thresholds for Force Majeure and Hardship are being tested.14
The Role Of The CISG In Trade Disputes
The UN Convention on Contracts for the International Sale of Goods (CISG) is increasingly perceived as a middle ground between common-law and civil-law jurisdictions in settling these disputes.36 Arbitral tribunals often apply the CISG without hesitation to trade disputes, as it provides a harmonized set of remedies that balance “specific performance” with “monetary compensation”.36
In the current environment, Article 79 of the CISG (exemption from liability) is particularly relevant. It offers guidelines for interpreting force majeure when a contract does not include a specific clause, though it is often excluded by parties from large economies who prefer their own more favorable local laws.36
Hardship And The Duty To Renegotiate
While Force Majeure typically requires a total “impossibility” of performance, Hardship (or rebus sic stantibus) focuses on events that fundamentally change the economic balance of the contract.14 In civil law jurisdictions like Italy or the Netherlands, an obligation to renegotiate in good faith may arise even if a hardship provision is missing from the contract.14
This is becoming a critical tool for parties struggling with the 2025 tariff shocks, allowing for price adjustments or a partial release from obligations rather than a total breakdown of the commercial relationship.14
Enforcement Challenges In A Fragmented Global Order
The ultimate value of arbitration lies in the enforceability of awards under the New York Convention (NYC).39 However, the current geopolitical climate has introduced new hurdles to recognition and enforcement, often centered on the “public policy” exception.39
Public Policy As A Narrow Vs. Broad Barrier
The interpretation of public policy varies widely across jurisdictions:
| Jurisdiction | Approach To Public Policy |
|---|---|
| Turkey And The UAE | Recent case law suggests a trend toward narrowing the scope of public policy objections, positioning them as a “last resort control mechanism” rather than a broad barrier to enforcement.27 |
| The United States | U.S. courts, such as the 11th Circuit in CME v. CVG Ferrominera, maintain a high threshold for public policy defenses, refusing to deny enforcement even when corruption is alleged in the underlying contract, as long as the award itself does not violate “basic notions of morality and justice”.43 |
| Russia | Russia has dramatically expanded the “public policy” exception to include the “nationality-based bias” of arbitrators from unfriendly states, creating a major rift in the uniform application of the NYC.20 |
Due Process And Notification Standards
Enforcement is also being challenged on “due notice” grounds. In a precedent-setting decision on March 20, 2025, the Danish Supreme Court denied enforcement of a Shanghai Arbitration Commission (SHAC) award.44 The court found that the respondent had not been properly notified, affirming that “actual receipt” of notification is the relevant standard in Scandinavia, regardless of whether a party appears to be evasive.44
This underscores that even in pro-enforcement jurisdictions, the procedural integrity of the underlying arbitration remains under intense judicial scrutiny.44
Future Outlook: Commercial Arbitration In 2026 And Beyond
As international commercial arbitration adapts to a world defined by “geopolitical turbulence, technological breakthroughs, and escalating ESG demands,” several key trends will define the field in 2026.45
- AI Adjudication And Efficiency: Next-generation AI will move beyond document review to take on more active case management roles.45 Strategic collaborations between institutions (e.g., LCIA and Jus Mundi) will accelerate the integration of AI into arbitral processes, though concerns regarding AI bias and the “right to a human arbitrator” will persist.46
- Climate And ESG Disputes: The pursuit of net-zero goals and the regulatory measures states take in response (e.g., the Inflation Reduction Act in the U.S. or the Sheinbaum administration’s reforms in Mexico) will generate a wave of new investor-state and commercial claims in the infrastructure and energy transition sectors.2
- Localized Arbitral Ecosystems: The growth of the AfCFTA and the continued rise of Asian seats will likely result in a “multi-polar” arbitration market.1 Regional jurisdictions will continue to innovate their laws to become more “arbitration-friendly” as a way to position themselves as global hubs.48
- Heightened Geopolitical Risk Management: Companies will move from a reactive to a proactive risk mitigation strategy, integrating “Trump measure clauses” and detailed “waterfall clauses” (cascading choices of arbitral institutions) into their agreements to ensure that if one seat becomes inaccessible due to sanctions, the dispute can seamlessly move to another.9
Conclusion
In conclusion, international commercial arbitration remains in “exceptionally robust health,” as evidenced by record caseloads and surging dispute values.5 However, the system is under intense pressure to balance efficiency with legitimacy in a world where trade policy is increasingly weaponized.4
The success of arbitration in the mid-2020s will depend on its ability to offer a truly neutral and predictable forum for resolution amidst the ongoing geopolitical realignment of the global economy.1
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https://en.nbpublish.com/library_read_article.php?id=39543
