• Provisional Remedies
With respect to the availability of provisional remedies, Article 17 of the Model Law gives arbitrators the power to order such interim relief ‘as the arbitral tribunal may consider necessary in respect of the subject matter of the dispute’. Article 9 recognizes that it is not incompatible with an arbitration agreement for a party to request interim measures of protection from a court and for a court to grant such measures before or during arbitral proceedings. The FAA, in contrast, is completely silent on the subject of the availability of provisional remedies—both from the arbitral tribunal and a court.