Comparing Model Arbitration Clauses: ICC vs. LCIA vs. SIAC

When negotiating contracts, especially those involving cross-border transactions, determining the method for resolving future disputes is critical. Generally, it is a safe and recommended approach to adopt a model arbitration clause provided by well-established arbitral institutions.

The International Chamber of Commerce ("ICC"), the London Court of International Arbitration ("LCIA"), and the Singapore International Arbitration Centre ("SIAC") all recommend that parties use their respective standard clauses to ensure clarity and enforceability. However, great care must be taken during drafting, as careless drafting can cause misunderstandings that may undermine the parties' intentions as to jurisdiction or even make the clause inoperable.¹