Resources
General
   
1.
Can SIAC provide legal advice?

SIAC is an independent and neutral arbitral institution. We therefore do not act on behalf of parties or provide legal advice.
   
2.
What are the benefits of arbitration in Singapore?

Singapore has been dubbed “the hub of all trades” and is widely recognised by parties doing business in the region as a seat of arbitration that is both neutral and geographically convenient for parties to a dispute. Singapore is also a party to the Convention on the Recognition and Enforcement of Foreign Arbitral Awards (New York, 1958) (the "New York Convention").

Arbitration is a less formal procedure than court litigation, and it is conducted in private, away from the glare of the media and the public. Parties are free to appoint their own arbitrators and can choose more practical procedures and rules for the conduct of an arbitration. Generally, arbitration can also be more cost-efficient and speedier than court litigation.

Furthermore, due to the fact that Singapore has adopted the UNCITRAL Model Law on International Commercial Arbitration (1985), one can expect maximum judicial support and minimal judicial interference from Singapore courts. Arbitral awards which are final and binding, are generally enforceable in approximately 150 countries under the New York Convention (subject to any local legislation and/or requirements).
   
3.
What types of disputes can be resolved by arbitration at SIAC? Is SIAC capable of administering all such disputes?

SIAC generally administers commercial, construction/engineering, corporate, shipping/maritime, trade and insurance arbitrations. However, as SIAC’s competence and jurisdiction to administer arbitrations is derived from the arbitration clause found in a contract, the types of disputes SIAC can administer are not necessarily limited to the above sectors but can potentially be any type of contractual dispute (subject to certain limitations).
   
4.
Is there a maximum or minimum claim amount?

There is no maximum or minimum claim amount for cases to be administered by SIAC.
   
5.
Can SIAC administer arbitrations in languages other than English?

The SIAC Secretariat is comprised of counsel who are fluent in, inter alia, Chinese, Korean, French, Hindi and Malay. If the arbitration clause so requires, SIAC is generally able to administer the case in languages other than English and has done so in the past, subject to translations being provided by the parties, as may be necessary.
   
6.
Can SIAC administer arbitrations where the governing law is not Singapore law?

Yes, SIAC is fully competent to administer arbitrations where the governing law is not Singapore law.
   
7.
Can SIAC administer arbitrations where the seat of arbitration is not Singapore?

Yes, SIAC can generally administer arbitrations where the seat of arbitration is not Singapore and has done so in the past.
   
8.
Should hearings in SIAC-administered arbitrations be held in Singapore?

Generally (and subject to any agreement to the contrary or other circumstances), hearings in SIAC-administered arbitrations do not have to be held in Singapore.
   
9.
Can two international parties having no connection with Singapore refer a case to SIAC for administration?

Yes. In fact, almost 50% of the new cases filed in 2013 have no connection to Singapore.
   
10.
How long do SIAC-administered arbitrations usually take?

Generally (and subject to the complexity of the dispute, the number of submissions and the respective schedules of the parties and the Tribunal), awards in disputes with sole member tribunals are usually rendered within 9 to 12 months, while awards in disputes with three-member tribunals are usually rendered within 12 to 18 months. Arbitrations administered according to the SIAC Expedited Procedure require awards to be rendered within 6 months from the constitution of a tribunal (subject to any extensions).
   
11.
What are SIAC’s operating hours?

SIAC’s operating hours are Monday to Friday, 9.00 am to 5.30 pm (Singapore time). SIAC is closed on public holidays in Singapore.
   
Arbitration agreements
   
12.
Does SIAC have a model arbitration clause?

In drawing up international contracts, we recommend that parties include the following arbitration clause:

Any dispute arising out of or in connection with this contract, including any question regarding its existence, validity or termination, shall be referred to and finally resolved by arbitration administered by the Singapore International Arbitration Centre (“SIAC”) in accordance with the Arbitration Rules of the Singapore International Arbitration Centre ("SIAC Rules") for the time being in force, which rules are deemed to be incorporated by reference in this clause.

The seat of the arbitration shall be [Singapore].*

The Tribunal shall consist of _________________** arbitrator(s).

The language of the arbitration shall be ________________.

Parties should also include an applicable law clause. The following is recommended:

This contract is governed by the laws of _________________.***

______________________________________________
* Parties should specify the seat of arbitration of their choice. If the parties wish to select an alternative seat to Singapore, please replace “[Singapore]” with the city and country of choice (e.g., “[City, Country]”).
** State an odd number. Either state one, or state three.
*** State the country or jurisdiction.

13.
We do not have an arbitration clause in our contract. Can we commence arbitration at SIAC?

SIAC’s jurisdiction to administer an arbitration is derived from the arbitration agreement. Therefore, without an arbitration clause or any other post-contractual agreement to refer the dispute to SIAC, SIAC cannot administer the arbitration.
   
14.
Is it sufficient if my arbitration clause provides simply for arbitration in Singapore?

A clause referring only to arbitration in Singapore does not provide for SIAC arbitration, though it does provide for an ad hoc arbitration seated in Singapore. Parties may, however, agree to adopt the SIAC Rules by agreement.
   
15.
Does SIAC act as an appointing authority?

Yes, the Chairman of SIAC is designated as the appointing authority in Singapore by statute (the International Arbitration Act (Cap. 143A) and the Arbitration Act (Cap.10) as may be applicable and in the manner provided therein). Hence, in ad hoc arbitrations seated in Singapore, where parties require an arbitrator to be appointed and subject to the arbitration agreement between the parties, SIAC can assist in making such appointments for a fee.

SIAC is also competent to, and frequently acts as, an appointing authority for arbitrations under the UNCITRAL Arbitration Rules, subject to the arbitration agreement between the parties.
   
16.
Does SIAC administer cases conducted under the UNCITRAL Arbitration Rules?

Yes, SIAC is able to administer arbitrations under the UNCITRAL Arbitration Rules, both 1976 and 2010 versions, where parties have agreed to SIAC administering the arbitration. SIAC has issued Practice Notes to provide guidance on its administration of such arbitrations. The Practice Notes are available here.
   
Commencement of arbitration at SIAC
   
17.
How do we commence an SIAC arbitration?

Arbitration is a consensual process; both parties will have to agree to submit the dispute to SIAC for arbitration. As a first step, parties have to check their agreement to find out if there is an arbitration clause referring the dispute to arbitration at SIAC. Even if there is none, parties can still agree to submit the dispute to arbitration at SIAC. This post-dispute agreement should be in writing. Once either step is fulfilled, a Notice of Arbitration has to be filed with the Registrar of SIAC along with payment of the requisite filing fee(s).
   
18.
How do we file the Notice of Arbitration?

The Notice of Arbitration may be filed with us via email, fax, by hand and/or by courier, to the attention of the Registrar. Our details are as follows:

Email: This email address is being protected from spambots. You need JavaScript enabled to view it.">This email address is being protected from spambots. You need JavaScript enabled to view it. (kindly ensure that the size of the email does not exceed 5 MB)
Fax: +65 6224 1882
Address: 32 Maxwell Road, #02-01 Maxwell Chambers, Singapore 069115.

A copy of the Notice of Arbitration should be sent to the Respondent(s), and the Claimant should notify us of the mode of service employed and the date of service.
   
19.
Can SIAC provide a sample Notice of Arbitration?

Unfortunately, we cannot provide a sample Notice of Arbitration. Although there is no prescribed format for a Notice of Arbitration, please refer to Rule 3.1 of the SIAC Rules, 2013 to ensure that all the requirements for a Notice of Arbitration have been complied with.
   
20.
Where should we file our Response to the Notice of Arbitration?

This email address is being protected from spambots. You need JavaScript enabled to view it."> The Response to the Notice of Arbitration may be filed with us via email, fax, by hand and/or by courier, to the attention of the Registrar. Our details are as follows:

Email: This email address is being protected from spambots. You need JavaScript enabled to view it.">This email address is being protected from spambots. You need JavaScript enabled to view it. (kindly ensure that the size of the email does not exceed 5 MB)
Fax: +65 6224 1882
Address: 32 Maxwell Road, #02-01 Maxwell Chambers, Singapore 069115.

A copy of the Response to the Notice of Arbitration should likewise be sent to the Claimant, and the Respondent should notify us of the mode of service employed and the date of service.
   
21.
How much are the Case Filing Fees?

Under the current Schedule of Fees, the Case Filing Fee for Singapore parties is SGD 2,140.00. The Case Filing Fee for non-Singaporean parties is SGD 2,000.00.
   
22.
Can I consolidate related cases?

SIAC’s Rules are silent on consolidation. Should the parties reach an agreement to consolidate related cases, consolidation would generally take place after the constitution of the Tribunal, upon the parties’ request, and pursuant to directions issued by the Tribunal.
   
23.
We want to file a counterclaim. Do we have to pay a filing fee for the counterclaim?

Yes. The Case Filing Fee is likewise payable for the counterclaim. Under the current schedule of fees, the Case Filing Fee for Singapore parties is SGD 2,140.00. The Case Filing Fee for non-Singaporean parties is SGD 2,000.00.
   
24.
What happens if the Claimant fails to pay the Case Filing Fee?

Pursuant to Rule 3.1(k) of the SIAC Rules, 2013, as the payment of the requisite filing fee is part of the requirements for filing a Notice of Arbitration, the Notice of Arbitration will not be deemed complete and the arbitration will not be deemed to have commenced until all the requirements of Rule 3.1 have been fulfilled.
   
25.
What happens if the counterclaimant fails to pay the filing fee?

If the counterclaimant fails to pay the filing fee, the counterclaim may be deemed as not filed.
   
26.
How do we pay the filing fees?

Payments may be made by a local cheque payable to “Singapore International Arbitration Centre” or by bank transfer to our bank account. For bank details, please contact us at +65 6221 8833 or email This email address is being protected from spambots. You need JavaScript enabled to view it..
   
Cost
   
27.
What do the costs of arbitration, as defined in the SIAC Rules, 2013 include?

The costs of arbitration include:
a. the tribunal’s fees and expenses;
b. SIAC’s administrative fees and expenses; and
c. the costs of expert advice and of other assistance required by the tribunal.

Costs of arbitration do not include legal fees and other costs.
   
28.
How are the costs of arbitration calculated?

In the first instance, when an arbitration commences, SIAC estimates the maximum costs of arbitration.

To arrive at a rough estimate of the costs of arbitration, our Fee Calculator which is available here may be useful.
   
29.
How much would arbitration proceedings with SIAC cost?

To arrive at a rough estimate of the costs of arbitration, our Fee Calculator which is available here may be useful.
   
30.
If we cannot quantify our dispute, how would SIAC estimate the costs of arbitration?

If the parties cannot quantify the amount of the claim or the counterclaim at the time payment is due, the Registrar will make a provisional estimate of the costs of arbitration based on the information known to us at the time of making the provisional estimate of costs. Under the SIAC Rules, 2013, the estimate may be based on the nature of the controversy and the circumstances of the case. This may be adjusted in light of such information as may subsequently become available.
   
Appointment of arbitrators
   
31.
Does SIAC maintain a Panel of Arbitrators?

Yes, SIAC maintains its own Panel of Arbitrators who are drawn from approximately 39 different jurisdictions. The panel and the CVs of each of the members is publicly available here.
   
32.
May a party nominate an arbitrator who is not on SIAC’s Panel of Arbitrators?

Yes. Parties to a dispute are free to nominate arbitrators of their choice, whether from the SIAC Panel of Arbitrators or not.
   
33.
Who are on SIAC’s Panel of Arbitrators?

The SIAC’s Panel of Arbitrators is comprised of some of the most experienced, qualified and prominent arbitrators from around the world. You may find the names and short CVs of the arbitrators on SIAC’s Panel of Arbitrators here.
   
34.
How do I apply to be on SIAC’s Panel of Arbitrators?

If you wish to make an application to be on SIAC’s Panel of Arbitrators, please send a completed application form and your curriculum vitae highlighting your arbitration experience, together with a non-refundable processing fee of S$535 (being S$500 plus 7% Goods and Services Tax (GST) which is applicable to both local as well as overseas applicants). Your application may also be accompanied by a covering letter and references (if any).

The application form and CV template are downloadable here.

Payments may be made by a local cheque payable to “Singapore International Arbitration Centre”. Please indicate your name, contact number and the words “Panel Application” on the reverse side of the cheque. Local cheques should be sent to the Registrar, Singapore International Arbitration Centre, 32 Maxwell Road, #02-01, Singapore 069115. Alternatively, payments may also be made by bank transfer to our bank account. For bank details, please contact us at +65 6221 8833 or email This email address is being protected from spambots. You need JavaScript enabled to view it..
   
35.
Should arbitrators be lawyers?

Generally (and subject to any agreement to the contrary), arbitrators do not have to be lawyers or have a legal background.
   
Party representation
   
36.
Do parties need to be represented by lawyers in SIAC arbitrations?

No, although recommended, parties to a dispute do not necessarily need to be represented by lawyers in SIAC arbitrations.
   
37.
Can parties be represented by lawyers who are not qualified in Singapore?

Yes. There are generally no restrictions on foreign law firms engaging in and advising on arbitration in Singapore. Likewise, non-residents generally do not require work permits to carry out arbitration services in Singapore.
   
Awards
   
38.
Are awards rendered in SIAC arbitrations enforceable outside Singapore?

Generally, awards in SIAC arbitrations would be enforceable outside Singapore. SIAC and Singapore awards have been enforced in various jurisdictions including Indonesia, China, Hong Kong, India, Australia, USA, Malaysia, Thailand, Vietnam and Jordan.
   
39.
Does SIAC scrutinise awards rendered by arbitral tribunals?

Yes, pursuant to Rule 28.2, prior to making any award, tribunals are required to provide them in draft form to the Registrar of SIAC. The Registrar may suggest modifications as to the form of the award and, without affecting the tribunal’s liberty of decision, may also draw the tribunal’s attention to points of substance. No award shall be made by a tribunal until it has been approved by the Registrar as to its form.
   
Appointment of arbitrator(s) in ad hoc cases
   
40.
Can SIAC appoint arbitrators in ad hoc cases?

Yes, SIAC accepts requests for appointment of arbitrator(s) in ad hoc cases, subject to the arbitration agreement between the parties.
   
41.
How much are SIAC’s appointment fees?

Under the current schedule of fees, the appointment fee for Singapore parties is SGD 3,210 for one arbitrator, SGD 4,280 for two arbitrators, and SGD 5,350 for three arbitrators. The appointment fee for non-Singaporean parties is SGD 3,000 for one arbitrator, SGD 4,000 for two arbitrators, and SGD 5,000 for three arbitrators.
   
42.
How do we pay the appointment fees?

Payments may be made by a local cheque payable to “Singapore International Arbitration Centre” or by bank transfer to our bank account. For bank details, please contact us at +65 6221 8833 or email This email address is being protected from spambots. You need JavaScript enabled to view it..
   
Special procedures
   
43.
What is the SIAC Expedited Procedure?

The Expedited Procedure is a special procedure that can be applied for by any party to an SIAC arbitration desiring an expeditious arbitral process.

A party may apply to the Registrar in writing for the arbitral proceedings to be conducted in accordance with the Expedited Procedure where any of the following criteria is satisfied:


a.
the amount in dispute does not exceed the equivalent amount of S$5,000,000, representing the aggregate of the claim, counterclaim and any set-off defence;
b. the parties so agree; or
c. in cases of exceptional urgency.
   
44.
Who decides if the case is fit for the Expedited Procedure?

The President of the SIAC Court of Arbitration considers the views of the parties, and thereafter determines whether the arbitral proceedings shall be conducted in accordance with the Expedited Procedure.
   
45.
What is the SIAC Emergency Arbitrator procedure?

The Emergency Arbitrator procedure is a special procedure that can be applied for by any party to an SIAC arbitration where the party requires urgent emergency interim relief prior to the constitution of the tribunal.
   
46.
How do I apply for emergency interim relief?

A party in need of emergency relief may, concurrent with or following the filing of a Notice of Arbitration but prior to the constitution of the tribunal, make an application for emergency interim relief. The party shall notify the Registrar and all other parties in writing of the nature of the relief sought and the reasons why such relief is required on an emergency basis.

The application shall also set forth the reasons why the party is entitled to such relief. Such notice must include a statement certifying that all other parties have been notified or an explanation of the steps taken in good faith to notify other parties. The application shall also be accompanied by payment of any deposits set by the Registrar.

Based on our current schedule of fees, emergency interim relief applications must be accompanied by payment of a non-refundable fee of SGD 5,350 for Singaporean parties, or SGD 5,000 for non-Singaporean parties.
   
Confidentiality
   
47.
Can I obtain information about parties to SIAC arbitrations?

Confidentiality is generally a key advantage of international arbitration. Arbitration proceedings conducted at SIAC are generally private and confidential in nature. Our response to any queries from the public for information on SIAC arbitrations is that we cannot comment on the existence or otherwise of such an arbitration at SIAC.
   
Parties at SIAC
   
48.
What kinds of parties typically use SIAC arbitration?

Parties from over 50 different jurisdictions were involved in SIAC arbitrations in 2013. For more information on statistics on our cases, please do refer to our Annual Reports, which are available here.
   
SIAC and Singapore Institute of Arbitrators (SIArb)
   
49.
Is there a difference between Singapore International Arbitration Centre (SIAC) and Singapore Institute of Arbitrators (SIArb)?

Yes, they are separate and distinct organisations.
   
SIAC and Singapore International Mediation Centre (SIMC)
   
50.
What is the difference between arbitration and mediation?

In arbitration, the arbitrator looks into the legal rights and wrongs of a dispute and makes a decision. Once the arbitrator has arrived at a decision, it is binding on parties whether they agree with it or not. It is very much like the way a court case is decided by a judge, except that the process does not take place in a courtroom, and it is not open to the public. As in a court case, there is usually a winning and a losing party in arbitration.

In mediation, the mediator essentially helps parties to settle their disputes by a process of discussion and narrowing differences. The mediator helps the parties to arrive at an agreed solution. He does not decide the dispute. A successful mediation results in an agreement signed by the parties, whereas a contested arbitration results in a decision by the arbitrator himself without the agreement of the parties. In mediation, there is no such thing as a winning or losing party, because there is no binding decision. Instead, the parties are free to agree on both legal and non-legal solutions suited to their interests and needs.

The Singapore International Arbitration Centre handles arbitration cases in Singapore. The Singapore International Mediation Centre manages international mediation cases in Singapore.

For more information on the Singapore International Mediation Centre, please click here.
   
51.
What is Arb-Med-Arb?

Parties who have signed an arbitration agreement and/or have commenced arbitration may wish to refer their dispute to mediation, either before they commence arbitration or in the course of the arbitration.

“Arb-Med-Arb” is a process where a dispute is first referred to arbitration before mediation is attempted. If parties are able to settle their dispute through mediation, their mediated settlement may be recorded as a consent award. The consent award is generally accepted as an arbitral award, and, subject to any local legislation and/or requirements, is generally enforceable in approximately 150 countries under the New York Convention. If parties are unable to settle their dispute through mediation, they may continue with the arbitration proceedings.

Under the SIAC-SIMC Arb-Med-Arb Protocol, the arbitrator(s) and the mediator(s) will be separately and independently appointed by SIAC and SIMC respectively, under the applicable arbitration rules and mediation rules of each Centre. Unless the parties otherwise agree, the arbitrator(s) and the mediator(s) will generally be different persons.
   
52.
Why Arb-Med-Arb?

Arb-Med-Arb is a flexible and efficient form of alternative dispute resolution. It combines the advantages of confidentiality and neutrality with enforceability and finality.

Both arbitration and mediation proceedings are confidential and can be conducted by a neutral third party at the parties’ venue of choice.

A settlement agreement obtained through the Arb-Med-Arb process may be made a consent award. The consent award is generally accepted as an arbitral award, and, subject to any local legislation and/or requirements, is generally enforceable in approximately 150 countries under the New York Convention.

Parties can therefore achieve finality whether through the mediation process or arbitration process.

Parties wishing to take advantage of this tiered dispute resolution mechanism as administered by SIAC and SIMC, may consider incorporating the following Arb-Med-Arb Clause in their contracts:

Any dispute arising out of or in connection with this contract, including any question regarding its existence, validity or termination, shall be referred to and finally resolved by arbitration administered by the Singapore International Arbitration Centre ("SIAC") in accordance with the Arbitration Rules of the Singapore International Arbitration Centre ("SIAC Rules") for the time being in force, which rules are deemed to be incorporated by reference in this clause.

The seat of the arbitration shall be [Singapore].*

The Tribunal shall consist of _________________** arbitrator(s).

The language of the arbitration shall be ________________.

The parties further agree that following the commencement of arbitration, they will attempt in good faith to resolve the Dispute through mediation at the Singapore International Mediation Centre ("SIMC"), in accordance with the SIAC-SIMC Arb-Med-Arb Protocol for the time being in force. Any settlement reached in the course of the mediation shall be referred to the arbitral tribunal appointed by SIAC and may be made a consent award on agreed terms.
______________________________________________
* Parties should specify the seat of arbitration of their choice. If the parties wish to select an alternative seat to Singapore, please replace "[Singapore]" with the city and country of choice (e.g., "[City, Country]").
** State an odd number. Either state one, or state three.

Press Releases

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SIAC Announces the Official Release of the SIAC Rules 2016

30 June 2016SIAC Announces the Official Release of the SIAC Rules 2016The Singapore International Arbitration Centre (SIAC) is pleased to announce the official release of the sixth edition of the Arbitration Rules of the Singapore International Arbitration Centre (“SIAC Rules 2016”). The SIAC Rules 2016 will be available on the SIAC website from 1 July 2016, and will come into e...

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SIAC Signs Memorandum of Agreement with GIFT

3 June 2016SIAC Signs Memorandum of Agreement with GIFT The Singapore International Arbitration Centre (SIAC) is pleased to announce that it has entered into a Memorandum of Agreement (MOA) with the Gujarat International Finance Tec-City Company Limited (GIFTCL) and GIFT SEZ Limited (GIFT SEZ). Under the MOA, SIAC, GIFTCL and GIFT SEZ will collaborate to promote the use of arbit...

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SIAC Announces Appointment of New Registrar and Promotion of Deputy Registrar

27 April 2016SIAC Announces Appointment of New Registrar and Promotion of Deputy RegistrarThe Singapore International Arbitration Centre (SIAC) is pleased to announce the appointment of Ms Delphine Ho as Registrar of SIAC with effect from 20 May 2016, and the promotion of its Deputy Registrar, Mr Kevin Nash, to Deputy Registrar and Centre Director, effective 1 May 2016. Ms Ho wi...

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SIAC Signs Memorandum of Understanding with Oe-Cusse Administration

28 March 2016SIAC Signs Memorandum of Understanding with Oe-Cusse AdministrationThe Singapore International Arbitration Centre (SIAC) is pleased to announce that it has entered into a Memorandum of Understanding with the Authority of the Special Administrative Region of Oe-Cusse Ambeno (SAROA) and Special Zones for Social Market Economy (ZEESM) Timor-Leste (SAROA-ZEESM TL), form...

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SIAC Announces Record Case Numbers for 2015

25 February 2016SIAC Announces Record Case Numbers for 2015 The Singapore International Arbitration Centre (SIAC) is pleased to announce the official release of its 2015 Annual Report at the SIAC Annual Appreciation Event this evening. 2015 was a milestone year for SIAC. SIAC recorded the highest ever number of cases filed, highest ever number of administered cases and highest e...

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Public Consultation on Draft SIAC Investment Arbitration Rules

1 February 2016Public Consultation on Draft SIAC Investment Arbitration RulesThe Singapore International Arbitration Centre (SIAC) is pleased to announce the commencement of the public consultation process on its draft Investment Arbitration Rules 2016 (the “draft IA Rules”), a comprehensive set of specialised rules for the administration of investment arbitrations by SIAC.The d...

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SIAC Appoints New Court Member

1 February 2016SIAC Appoints New Court MemberThe Singapore International Arbitration Centre (SIAC) is pleased to announce the appointment of Mr Darius Khambata, Senior Counsel, to the SIAC Court of Arbitration with effect from 1 February 2016.Mr Khambata practises before the Bombay High Court and the Supreme Court of India. He has previously held two distinguished public law off...

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Opening of SIAC Office in Shanghai

25 January 2016Opening of SIAC Office in ShanghaiThe Singapore International Arbitration Centre (SIAC) is pleased to announce the opening of a representative office in the China (Shanghai) Pilot Free Trade Zone (FTZ). The launch of the Shanghai office underpins SIAC’s steadily growing popularity amongst Chinese parties, and is an integral part of SIAC’s continuous efforts to for...

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Public Consultation on Draft SIAC Arbitration Rules

18 January 2016Public Consultation on Draft SIAC Arbitration RulesThe Singapore International Arbitration Centre (“SIAC”) is pleased to announce the opening of the public consultation process on its draft revised Arbitration Rules 2016 (the “draft Rules”). The revision of SIAC’s Arbitration Rules takes into account recent developments in international arbitration practice and pr...

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