The Court granted confirmation of an award rendered in New York between two Haitian parties. The respondent argued that it had been unable to defend itself in the arbitration – an argument that the Court constructed as being brought under Art. V(1(b) of the New York Convention – because the arbitrators had held a hearing in the middle of a COVID-19 surge in Haiti, less than three weeks after the assassination of Haiti's President, and despite the respondent's request that the hearing be postponed. The Court concluded that while these were certainly significant and relevant factors to consider, the record showed that the respondent did have an opportunity to present its case at the arbitration hearing, which was conducted in New York. The Court also denied the contention that the arbitral panel had been improperly formed because two of the arbitrators were former partners of the claimant's counsel in a law firm, and the third arbitrator was directly associated with the same counsel via membership in an organization. The Court explained that Art. V(1)(d) of the Convention merely required that the arbitrators be selected in accordance with the terms of the arbitration agreement, and that the arbitrators had been so selected in this case. The Court finally rejected the claim that enforcing the improperly procured award against against a longstanding ally was contrary to the public policy of the United States within the meaning of the public policy exception in Art. V(2)(b) of the New York Convention. The Court noted that the law of the Circuit was that this exception had to be construed very narrowly to encompass only those circumstances where enforcement would violate the most basic notions of morality and justice. This was not the case here, and enforcement would actually further the United States' strong public policy in favor of international arbitration