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Abstract

Controversy continues over the “public policy” exception set out in the New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards. Claims are still made regarding the sharpness of distinctions between national and international law and private international law and public international law. Populist assertions of sovereignty have given these supposed distinctions even greater salience. A closer assessment of national and international law suggests, however, that the distinctions are not as sharp as some have contended.

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