• Journal of Arbitration Studies
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• v.23 no.4
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• pp.123-138
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• 2013

The surge of cross border trade and transactions has seen international arbitration fast emerging as the preferred mode of dispute resolution. This phenomenon is especially remarkable in the Asian region. The Singapore International Arbitration Centre ("SIAC") aspires to contribute to this growth as one of the leading arbitral institutions. The objective of this article is to provide an insight into the key features of SIAC Rules. This article has been divided into two parts; the first part discusses how the SIAC Rules are helpful in building bridges in international arbitration between the common law and civil law systems. We have attempted to throw light on how the SIAC Rules may be tailored by the parties to bring about a harmonization in the common law and civil law practices in the conduct of the arbitration proceedings. In the second part of the article, we discuss the two most popular procedures introduced in the SIAC Rules in 2010 i.e. 'Emergency Arbitration' and 'Expedited procedures'. The emergency arbitration provisions enable a party to obtain order(s)/award for urgent interim relief(s) upon commencement of arbitral proceedings but pending the constitution of the main Tribunal. The expedited Procedure provisions give parties the option of having their disputes determined in six (6) months from the date of the constitution of the tribunal.

• Journal of Arbitration Studies
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• v.23 no.1
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• pp.177-200
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• 2013

Recently, many international arbitration institutions have responded to the business requirements of their users and have revised their rules to enhance the time and cost efficiency. Korean Commercial Arbitration Board (KCAB) revised the international arbitration rule in 2011, introducing new arbitration mechanisms like the expedited procedure. Also other Asian arbitration institutions introduced the expedited procedure in their international arbitration rules. Now expedited procedures are regarded as a very attractive system in the field of international arbitration. Accordingly, this paper reviewed the expedited procedures of four Asian countries, including China(CIETAC), Hong Kong (HKIAC), Singapore(SIAC) and Korea(KCAB). The purpose of this study is to find out meaningful implications to improve the Korean system. Based on this review, some recommendations are suggested as follows. First, the scope of the expedited procedure has to be adjusted upward than the current 200 million won. Second, there should be a fee schedule only for the expedited procedure. Third, in case of small amount international disputes, written examination should be more used in the expedited procedure. Finally, KCAB should make strong efforts to improve the awareness and usage of the expedited procedure in Korea.

• Journal of Arbitration Studies
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• v.16 no.3
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• pp.217-230
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• 2006

Singapore is a dual-track arbitration regime. Where seat of arbitration is Singapore, the governing procedural law for domestic arbitration is AA and for international arbitration is IAA. The parties may by agreement opt-out of and opt-into a specific regime. SIAC is a leading arbitral institution in Singapore. It offers wide range of services: administer arbitration proceedings, arrangement of logistics for arbitration hearing, appointment of arbitral tribunal for ad hoc arbitration in Singapore as well as registry and authentication of arbitral awards.

• Journal of Arbitration Studies
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• v.24 no.2
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• pp.137-160
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• 2014

These days, in line with the increase of opportunities in our country's firms to do transaction, large-scale M&A and investment with foreign firms incorporating arbitration clauses in the contracts have become general practice. Recently, Singapore has come to the fore as a place of arbitration and, particularly, Singapore International Arbitration Center (SIAC) was assessed as the favored international arbitration institution uniquely in Asia at the 2010 International Arbitration Survey: Choices in International Arbitration, along with the ICC, LCIA, and AAA/ICDR. Therefore, the country's firms need to understand properly the international arbitration procedure of Singapore. This study examines the international arbitration system of Singapore, focusing on the arbitration procedure of the SIAC. The Center revised arbitration rules twice in 2010 and 2013, and established the Court of Arbitration of SIAC in April 2013 for the first time in Asia in pursuit of stricter neutrality and promptness. It further seeks to run the arbitration procedure fairly by selecting a third country's people as an arbitrator, while its arbitration expenses are cheaper than those of the ICC. The study believes that for the country's international arbitration institutions such as the KCAB to jump forward as a world-class international arbitration institution, the Korean government should render positive support to them, learning from Singapore which does not spare any political and financial assistance to cultivate international arbitration institutions. On the other hand, KCAB should also try hard to improve in the aspects of neutrality, fairness, and promptness and to be selected as a trustworthy international arbitration institution by firms in Asian countries.

• KSII Transactions on Internet and Information Systems (TIIS)
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• v.8 no.8
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• pp.2881-2894
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• 2014

In complicated environment, context information plays an important role in image segmentation/labeling. The recently proposed auto-context algorithm is one of the effective context-based methods. However, the standard auto-context approach samples the context locations utilizing a fixed radius sequence, which is sensitive to large scale-change of objects. In this paper, we present a scale invariant auto-context (SIAC) algorithm which is an improved version of the auto-context algorithm. In order to achieve scale-invariance, we try to approximate the optimal scale for the image in an iterative way and adopt the corresponding optimal radius sequence for context location sampling, both in training and testing. In each iteration of the proposed SIAC algorithm, we use the current classification map to estimate the image scale, and the corresponding radius sequence is then used for choosing context locations. The algorithm iteratively updates the classification maps, as well as the image scales, until convergence. We demonstrate the SIAC algorithm on several image segmentation/labeling tasks. The results demonstrate improvement over the standard auto-context algorithm when large scale-change of objects exists.

• Journal of Arbitration Studies
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• v.22 no.3
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• pp.215-238
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• 2012

This paper is to review the interim measures of arbitral tribunals in international commercial arbitration and to compare the emergency arbitrator systems of international arbitration institutions including the ICDR, SCC, SIAC, ACICA, and ICC. Most arbitration legislation and arbitration rules permit the arbitral tribunal to grant orders for interim measures of protection. Orders for interim measures by the arbitral tribunal are not self-enforcing. However, the revised articles with regard to interim measures of UNCITRAL Model Law of 2006 are regarded to contribute significantly to the effectiveness of interim measures in international commercial arbitration. A party that needs urgent interim or conservatory measures that cannot await the constitution of an arbitral tribunal may make an application for such measures. Major international arbitration institutions have their own rules and provisions for the emergency arbitrator system, which was set forth first by the ICRD in 2006. The application requirements for emergency arbitrators are almost the same. However, there are significant differences in details such as appointments and applications for challenging emergency arbitrators, the process and form of the emergency arbitrator's decision, etc. Therefore, it will be necessary to consider these differences for more desirable emergency arbitrator proceedings in Korea.

• THE INTERNATIONAL COMMERCE & LAW REVIEW
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• v.64
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• pp.99-128
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• 2014

Last year, Seoul International Dispute Resolution Center(SIDRC) was set up to facilitate and promote international arbitration in Korea. This study was focused on the revision of arbitration rules such as ICC, SIAC, HKIAC and JCAA. As a leading arbitration institution in the world, ICC has tried continuously to provide more efficient service to their client by adopting emergency arbitrator(EA) & multi party arbitration. Other three institutions also introduced almost same mechanism to compete each other. These two new system is very innovative in international arbitration. First of all, EA was designed to provide interim measure service to preserve or protect parties' right before the constitution of arbitral tribunal. Arbitration institutions and arbitral tribunals should be careful to decide these requests are legitimate or not because too hasty approval on joinder or consolidation without full consideration such as parties' intention or argument may issue another serious problem - setting aside an award rendered after joined or consolidated.

• Journal of Arbitration Studies
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• v.31 no.3
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• pp.91-107
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• 2021

The Korean Association of Arbitration Studies faces its 30th anniversary in 2020 since its foundation in 1991 and is being celebrated and congratulated across the communities in and out of the country. However, the association seems to be standing at crossroads between a negative and positive direction. As shown in the past KAAS pattern in its academic activities, the academic community tends to focus relatively more on domestic issues, expanding its domestic network rather than international network for the past years. KAAS needs to turn its face to see the other side of the world, stretching its hands to the people outside first. For this purpose, this paper suggests that KAAS should strengthen its cooperative capability through the international cooperation division. KAAS' past 30 years of accumulated know-how and its academic network will play critical roles i-n expanding its partners across the global academic community. This paper delivers special thanks to the institutions, including the LMAA, CAC, SIAC, HKIAC, RSPP/ACRU, IDAC, and LAMC who sent cooperative works and congratulatory messages to KAAS 30th anniversary despite the COVID-19 pandemic situation.

• Journal of Arbitration Studies
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• v.29 no.4
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• pp.101-120
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• 2019

This study examines the development strategies of the arbitration industry in Singapore and Hong Kong, and its purpose is to provide implications for the development of the arbitration industry in South Korea. The main strategies implemented by Singapore and Hong Kong to develop the arbitration industry are as follows: first, improvement of the arbitration law system; second, active support of the government for promoting the arbitration industry; third, build up of an effective arbitration expert training system; and fourth, an arbitration-friendly attitude of the court. In order for South Korea to become an international arbitration hub in Northeast Asia, it is necessary to refer to the above-mentioned strategies. In addition, South Korea needs to develop marketing strategies that can differentiate itself from Singapore and Hong Kong, such as the development of an arbitration system in connection with the 4th Industrial Revolution, differentiation of the disputes sector, use of geographical advantages and a penetration pricing strategy, and support of the Korean Commercial Arbitration Board. In terms of marketing strategy, there are few studies on the development strategy of the arbitration industry in South Korea. In this respect, this study has academic value and differentiation.

• Journal of Arbitration Studies
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• v.30 no.1
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• pp.67-86
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• 2020

In the case of multiple commerce contracts in commerce, as well as multiple contracts related to it, a solution for the merging of arbitration proceedings is necessary in order to ensure uniformity of dispute resolution. Since the arbitration proceedings are based on the parties' agreement, no merging of two or more arbitration proceedings may transpire unless all parties agree. Claims of merging in arbitration proceedings lead to problems such as lack of party autonomy, resulting from lack of consent of the parties to merging, and how to appoint an arbitrator in a multilateral arbitration proceeding. Many of the major arbitration bodies have recognized the significant benefits of the terms of consolidation, and have recently revised the Arbitration Rules to include or extend existing clauses to reflect the needs of the parties. This study introduces the merging provisions of several selected major arbitration rules, such as the ICC, Switzerland, SCC, LCIA, SIAC, HKIAC, ACICA, and UNCITRAL rules, and looks at the main similarities and differences among the rules.