The court discusses the determination and relevance of the place where the award was made (in a foreign State or another contracting State.

The court discusses issues relating to the identity of the party against whom enforcement of the arbitral award is sought, including: piercing of the corporate veil, succession, assignment, State or State entity, group of companies, agent or principal, etc. For the related defenses to enforcement, see Art. V(1)(a).

The court discusses questions relating to interest on the amount due under the arbitral award, including whether the enforcement court may grant interest not granted in the award, modify interest granted in the award, and grant post-award interest.

The court discusses the overall scheme and/or pro-enforcement bias of the Convention.

The court discusses the burden of proof of the grounds for refusing enforcement under the Convention.

Due process: The court discusses what constitutes “proper notice” of the appointment of the arbitrators or of the arbitration proceedings.