Maghreb laws have progressed from a phase of hostility toward both arbitration and foreign arbitral awards, to a more moderate position. However, current Maghreb laws and rules on enforcement of foreign awards are not harmonized. Differences in the level of influence from international trends, especially the UNCITRAL Model Law, help explain the divergence. Efforts towards harmonization of regional law and the imminent ratification of the New York Convention by countries that have failed to do so until now promises a better future for arbitration in the Maghreb region.
Journal of International Arbitration