Why the model law has not been adopted in the UNITED STATES?
Unlike many other countries that are major venues for international arbitration, the UNITED STATES has not enacted the UNCITRAL model law. In the US, the 80-year old federal arbitration act (‘FAA’) provides the legislative framework for virtually all domestic and international commercial arbitration. Like the Model Law, the FAA supports the principles of party autonomy and limited local curial involvement in the arbitration. Under the FAA, like the Model Law, arbitration agreements are to be enforced in accordance with their terms and arbitral awards shielded from judicial review on the merits.