A Comparison of Singapore and Hong Kong’s Third-Party Funding Regimes to England and Australia - Arbitration: The International Journal of Arbitration, Mediation and Dispute Management View A Comparison of Singapore and Hong Kong’s Third-Party Funding Regimes to England and Australia by - Arbitration: The International Journal of Arbitration, Mediation and Dispute Management A Comparison of Singapore and Hong Kong’s Third-Party Funding Regimes to England and Australia 87 2

Singapore and Hong Kong have both recently reformed their international arbitration statutes to permit third-party funding of international arbitration, albeit subject to regulation. Meanwhile, the United Kingdom and Australia have operated as mature third-party litigation funding markets for many years with little regulation. This article considers the historical objections to third-party funding and compares the regulatory framework for third-party funding in England and Australia to Hong Kong and Singapore. It also examines relevant provisions in the rules of the major arbitral institutions in each of these jurisdictions. It concludes that Singapore and Hong Kong have proceeded cautiously, preferring greater regulation for third-party funding than England and Australia. This is a welcome development for an industry often thought to profit too generously at the expense of funded clients.

Arbitration: The International Journal of Arbitration, Mediation and Dispute Management