The Court of Appeal held that by agreeing to the arbitration clause in the contract with General Dynamics – which provided that the award shall be final, binding and wholly enforceable – Libya had waived immunity from execution. The Court reasoned that while it was well established that states can submit to another state’s (recognition) jurisdiction without consenting to execution against their property – such is the case under the New York Convention and the ICSID Convention – a straightforward reading of the clause at hand, particularly of its reference to the ICC Rules, by which the parties undertake to carry out any award without delay, justified the conclusion that the parties had consented to both the adjudicative and enforcement jurisdiction.